Advanced Partnerships LLC Privacy Notice

Effective: August 10, 2016

1. Introduction

We at Advanced Partnerships LLC (“VeraSafe”) know that your privacy is important. This privacy notice explains how we collect and use the data you provide to us. This privacy notice applies to our website VeraSafe.com including our dispute resolution program. This privacy notice also applies to your communication with us by phone, fax, email, and mail.

In the context of this privacy notice, VeraSafe acts as a data controller for the data we process.

In the case that you are a current or former client of VeraSafe and have signed a Master License Agreement, a Master License and Services Agreement, or a Technical and Professional Services Agreement with us, and where certain data protection provisions of any such agreement conflict with the terms of this notice, the terms of such agreement shall control.

2. Privacy Shield and Safe Harbor Compliance

Advanced Partnerships LLC complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the processing of personal data (“PII”). Advanced Partnerships LLC has certified that it adheres to all applicable provisions of the Privacy Shield Framework, including the Privacy Principles, the Supplemental Principles, and Annex 1 of the Framework. To learn more about the Privacy Shield program, and to view Advanced Partnerships LLC’s certification, please visit https://www.privacyshield.gov/list.

Advanced Partnerships LLC complies with the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of PII from European Economic Area member countries and Switzerland. Advanced Partnerships LLC has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Advanced Partnerships LLC’s certification, please visit http://www.export.gov/safeharbor/.

3. Data We Collect

Data You Provide To Us

In some situations, you may provide us with your personal data. Depending on your relationship with us, we may ask you for:

  1. biographical information such as your name;
  2. contact information such as your email address, mailing address, phone number, and fax number;
  3. professional information such as your job title, position, and information about your company or business; and
  4. credit card/debit card data including payment card number.

You may provide us with your personal data when you:

  1. make a purchase from us;
  2. submit a complaint or dispute to us concerning a business that participates in VeraSafe Program(s);
  3. complete a survey or questionnaire that we sent you or we invited you to take;
  4. submit a contact form on our website;
  5. subscribe to our blog updates;
  6. use the live chat feature on our website;
  7. subscribe to our email notifications or newsletters;
  8. register a user profile on our website; and
  9. contact us by any other means, such as by phone or email.
Data We Automatically Collect

When you access our website, whether by computer, mobile phone, or other device, we automatically collect certain data about your use of our website. To do this we use technologies such as cookies. The data we collect using cookies may include without limitation:

  1. geographical location and IDs of your computer, mobile or other device;
  2. bandwidth used;
  3. system and connection performance;
  4. browser type and version;
  5. operating system;
  6. length of visit;
  7. page views;
  8. referral source;
  9. IP address or other unique identifier for your computer, mobile phone, or other device; and
  10. your mobile carrier.

This data is not linked to your PII, unless you consider an IP address to be PII, as most or all of this data is typically associated with the IP address you were assigned at the time when we collected such data.

4. How We Use Your Data

How and why we use Cookies

We use session cookies, which are cookies that are deleted when you leave our website and persistent cookies, which are cookies that remain after you leave our website so that you are recognized when you return. Zopim (our live chat provider) and Google both drop persistent cookies from our website.

We may use your IP address to:

  1. help diagnose problems with our web servers;
  2. administer our website;
  3. analyze trends;
  4. track users’ movement;
  5. investigate security incidents;
  6. gather broad demographic information for aggregate use in order for us to improve the website; and
  7. deliver customized content.
We use data we automatically collect to:
  1. improve your experience on our website;
  2. count users who visit our website;
  3. improve the delivery of our ads and web pages to you; and
  4. help us better manage content and measure traffic on our website.

The use of cookies is industry standard so your web browser may be set to accept cookies. If you would prefer not to accept cookies, you can alter the configuration of your browser to reject all cookies or some cookies. Note, if you reject certain cookies, you might have trouble using some of the features on our website.

How and Why We Use Your Personal Data

We may use your PII to:

  1. respond to your inquiries, and/or other requests or questions;
  2. enable your use of the services available on our website;
  3. facilitate your verification and admission into our Programs(s);
  4. investigate and mediate disputes and complaints that you file with VeraSafe concerning a Participant in our Program(s);
  5. contact you regarding your purchase;
  6. enforce our copyrights or other important legal rights;
  7. collect payments from you;
  8. deliver services purchased through our website or over the phone;
  9. send you information and updates related to your purchase;
  10. send you invoices;
  11. send you email notifications which you have specifically requested;
  12. send you email marketing communications relating to our business which we think may be of interest to you; and
  13. send you email messages containing company news, product, or service information.

We may also use your PII for other purposes that are compatible with these purposes listed above.

Basis for Processing

Whenever possible, we process your PII based on your consent. In some cases, we may process your PII based on a contract entered into between us and you, or between us and a third party acting on your behalf.

5. Posting in Public Areas of Our Website

We may select and post customer testimonials on our website. These submissions may contain PII such as your name and the city, state, and country in which you live. We will obtain your consent prior to posting any testimonial that contains your PII.

If you allow us to post such content, it will be available to other users of the website. Your posting may also become public and we cannot prevent such data from being used in a manner that may violate our privacy notice or the law.

If you would like us to remove or delete your name or testimonial or review from our website, you may contact us at privacy_notice@verasafe.com.

Note that copies of data that you have updated, modified, or deleted may remain viewable in cached and archived pages of our website.

6. Data Security

VeraSafe has implemented and maintains commercially reasonable measures to protect against unauthorized access to and unlawful interception or processing of PII we process. Unfortunately, data transmission over the Internet is never 100% secure so we cannot guarantee the security of any data you transmit to us or from our website therefore you use our website and you communicate with us at your own risk.

If you register on our website, you are responsible for protecting the security of your user name and password. You are responsible for any transaction made using your user name and password.

All credit card data, passwords, and contact forms you submit via our website are encrypted prior to transit over the Internet using Transport Layer Security (formerly known as “SSL”).

7. How to Change or Update Your PII

You can access, change, or update PII you have provided and your preferences regarding information you receive from us by starting a support ticket with VeraSafe. To do this, please send your request via email to support@verasafe.com. You may also contact VeraSafe using the information found in the Contact Us section of this privacy notice to exercise your rights described in this section. We will implement any requested changes as soon as we reasonably can, subject to reasonable limitations, such as the need to verify your identity.

When you edit your data or change your preferences, data that you remove may remain in our databases or backup media because it is not always possible to completely remove or delete data from those locations.

Opting Out

You have a right to object to our processing of your personal data, except as required by law. You may also request updates or changes to your information or your preferences regarding receiving future promotional messages from us.

To do this you may contact our Privacy Officer using the information in the Contact Us section of this privacy notice.

Please note that if you opt out of receiving our promotional or marketing emails, you may still receive certain communications from us, such as administrative and services announcements and messages about your account.

8. Disclosure of Your Data

We may disclose your PII:

  • to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders; or
  • if we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change; or
  • to our vendors if necessary in order to provide you with service as further described in the section below.

After you agree to participate in and be bound by VeraSafe Program(s), your status in the Program(s) and any contact information you elect to share publically shall be considered public information. VeraSafe may make references to you and your name and URL on the VeraSafe website.

If you file a dispute with VeraSafe against a Participant in our Program(s) we will obtain your consent before sharing any of your submission with the Participant.

Onward Transfer to Data Processors

We may use third party vendors to perform certain services on our behalf, such as those:

  • hosting our website;
  • hosting our customer relationship management software as a service;
  • hosting our live chat software as a service;
  • hosting our company email server;
  • processing your payments;
  • maintaining, enhancing, or adding to the functionality of our website;
  • operating our website’s features;
  • fulfilling and processing orders;
  • assisting with promotions;
  • collecting web analytics data; and
  • enabling us to send you email, or performing other administrative services.

We may share your PII with these third party vendors solely to enable them to perform the services for us. We require that those third party vendors maintain at least the same level of data protection that we maintain for such data. However, some of our vendors may process your data outside of the United States.

We reserve the right to use, transfer, sell, and share aggregated, anonymous data, which does not include any PII, about our website’s users as a group for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients, and customers.

We do not provide your PII to parties unconnected with the services we provide. Except as disclosed in this privacy notice, we will not provide your data to third parties.

We are not responsible for the processing of your PII or any of your information by any third party, other than those third parties acting as our subcontractors to process data on our behalf. VeraSafe remains liable and responsible for the data processing operations undertaken by our subcontractors on our behalf.

Third Party Websites

Our website contains links to third party content and websites that we do not control. This includes links to clients, sponsors and partners. Note: if you click on these links and enter third party websites those third parties may use their own cookies to collect your data. You should read the third parties’ privacy notices to learn how they will collect and use your data as their policies may differ from ours and will apply to your use of their websites.

9. Privacy of Children

Our website is not directed at, or intended for use by, children under the age of 13. While we don’t typically know the age of our data subjects, we do not knowingly allow anyone under 18 to provide any PII to us.

If you believe your child may have provided us with PII, you can contact our Privacy Officer using the information in the Contact Us section of this privacy notice and we will undertake all reasonable efforts to delete the data.

10. Changes to this Privacy Notice

We may update this privacy notice from time to time by posting a new version on our website. You should visit this page occasionally to ensure you agree with any changes. We will post our revised privacy notice on our website and update the “Effective” date above to reflect the date of the changes.

By continuing to use our website after we post any such changes, you accept the privacy notice as modified.

11. Questions or Concerns, Contact Us

If you have a complaint, dispute, or question regarding this privacy notice or our processing of your data, please write to our Privacy Officer by email at privacy_notice@verasafe.com or by postal mail at:

Attn: Privacy Officer, Advanced Partnerships LLC
22 Essex Way, #8203
Essex, VT 05451
USA

You may also contact us by phone at our customer support number 1-888-376-1079 (or if calling from outside the U.S. dial +1-617-398-7067).

We will respond to your inquiries within 30 days of receipt.

12. Dispute Resolution Under the U.S.-Swiss Safe Harbor and EU-U.S. Privacy Shield Frameworks

If a complaint or dispute cannot be resolved through VeraSafe’s internal process, VeraSafe has agreed to cooperate with the EU Data Protection authorities and the Swiss Federal Data Protection and Information Commissioner and to participate in the dispute resolution procedures of the panel established by the EU Data Protection authorities.

Binding Arbitration

If your dispute or compliant can’t be resolved by VeraSafe, nor by the panel established by the EU Data Protection authorities or through the Department of Commerce, you may have the right to require that VeraSafe enter into binding arbitration with you pursuant to the Privacy Shield’s Recourse, Enforcement and Liability Principle and Annex I of the Privacy Shield.

Regulatory Oversight

Advanced Partnerships LLC is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.