Privacy Policy

This Policy

This Policy is issued by Versa and for purposes of this Privacy Policy, the term “visitor” includes visitors to our websites (our “Site”) who are not yet Customers, those who become Customers, as well as those who do not become Customers; whether you upload information to our websites, download content, or are merely visiting our websites. You can choose not to provide certain information when using our websites but then you might not be able to use all features. Defined terms used in this Policy are explained in the Definitions Section below.

Except as stated below, for the purposes of this Policy, Versa is the Controller. Contact details are provided in the Contact Section below.

Changes

Versa may change this Privacy Policy from time to time by posting a new Privacy Policy on its website. You should check our website to see recent changes, however, we will not materially change our privacy policies and practices described herein to make them materially less protective of personal information collected in the past without informing you of any such change.

Processing your Personal Data

Collection of Personal Data:

We may collect Personal Data about you, such as your name, address and contact details. Examples of sources from which we may collect Personal Data include, but are not limited to, the following:

We may obtain your Personal Data when you provide it to us (e.g., where you contact us via email or telephone, in person, or by any other means).
We may collect your Personal Data in the ordinary course of our relationship with you (e.g., in the course of administering your Versa account).
We may collect Personal Data that you manifestly choose to make public, including via our Site.
We may receive your Personal Data from third parties who provide it to us (e.g., social media platforms via plugins).
We may build out Customer / prospect profiles using third party sales tools, as well as by doing additional research on the web to obtain other personal details to enable a productive sales conversation.
We may collect or obtain Personal Data when you visit our Site, or use any features or resources available on or through our Site. When you visit our Site, your device and browser will automatically disclose certain information, some of which may constitute Personal Data (see below).

Creation of Personal Data:

We may also create Personal Data about you, such as records of your interactions using our Site and details of your account history.

Categories of Personal Data:

The categories of Personal Data about you that we may Process include

Personal details: given name(s); preferred name; preferences; and account settings.
Contact details: telephone number; email address; and social media profile details.
Professional details: professional profile details; title, association memberships; qualifications and company insight data.
Device details: device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to our Site and other technical communications information.
Usage details: records of your use of our Site and other services, including: registrations; details of content with which you interact; votes; questions; downloads; ratings; feedback; profile views; search queries; anonymous viewings; pageviews; player clickstream; chapters; and favorite moments.
Analysis data: keywords, communities, trends, content quality and content importance.
Views, opinions and interests: any comments, ratings, views or opinions that you choose to send to us, post via our Site, via a survey, or publicly post via social media platforms; your community interests and solution interests.

Lawful basis for Processing Personal Data:

In Processing your Personal Data in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:

we have obtained your prior express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary - it is not used for Processing that is necessary or obligatory in any way);
the Processing is necessary in connection with any contract that you may enter into with us;
the Processing is required by applicable law;
the Processing is necessary to protect the vital interests of any individual; or
we have a legitimate interest in carrying out the Processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.

Processing your Sensitive Personal Data:

We will not intentionally collect or maintain, and do not want you to provide, any information regarding your medical or health condition, age, race or ethnic origin, political opinions, or religious beliefs or other sensitive information.

We do not seek to collect or otherwise Process your Sensitive Personal Data except where:

the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);
the Processing is necessary for the establishment, exercise or defense of legal rights; or
we have, in accordance with applicable law, obtained your prior explicit consent prior to Processing your Sensitive Personal Data (as above, this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Purposes for which we may Process your Personal Data:

The purposes for which we may Process Personal Data, subject to applicable law, include:

Our Site: operating and managing our Site; providing content to you; displaying advertising and other information to you; and communicating and interacting with you via our Site.
Provision of services to you: providing our Site and other services to you (including suggesting content that may be of interest to you, based on your past activity); communicating with you in relation to those services; recommending content that may be of interest to you; and recommending your content to others.
Marketing communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law.
Communications and IT operations: management of our communications systems; operation of IT security; and IT security audits. We also use this information to prevent or detect fraud or abuses of our Website and to enable third parties to carry out technical, logistical or other functions on our behalf.
Health and safety: health and safety assessments and record keeping; and compliance with related legal obligations.
Financial management: sales; finance; corporate audit; and vendor management.
Surveys: engaging with you for the purposes of obtaining your views on our Site or our services.

Disclosure of Data to Third Parties

In addition, we may disclose your Personal Data to our partners, subject always to compliance with the terms of this Policy and the requirements of applicable law;

legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
accountants, auditors, lawyers and other outside professional advisors to Versa, subject to binding contractual obligations of confidentiality;
third party Processors (such as IT service providers; social media plugin providers; etc.), located anywhere in the world, subject to the requirements noted below in this Section “International Transfer of Personal Data”
any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;
any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security;
any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
our Site may use third party plugins or content (e.g., social media plugins). If you choose to interact with any such plugins or content, your Personal Data may be shared with the third party provider of the relevant social media platform.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

International Transfer of Personal Data

Because of the international nature of our business, we may need to transfer your Personal Data within Versa, and to third parties as noted in Section “Disclosure of Data to Third Parties”, in connection with the purposes set out in this Policy. For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements than those that apply in the country in which you are located.

Where we transfer your Personal Data to other countries, we do so on the basis of Standard Contractual Clauses. You may request a copy of our Standard Contractual Clauses using the contact details provided in Contact Section below.

Data Security

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law.

You are responsible for ensuring that any Personal Data that you send to us are sent securely.

Data Accuracy

We take reasonable steps designed to ensure that:

your Personal Data that we Process are accurate and, where necessary, kept up to date; and
any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

Data Minimization

We take reasonable steps designed to ensure that your Personal Data that we Process are limited to the Personal Data reasonably required in connection with the purposes set out in this Policy.

Data Retention

The criteria for determining the duration for which we will keep your Personal data are as follows: we will retain copies of your Personal Data in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. In particular, we may retain your Personal Data for the duration of any period necessary to establish, exercise or defend any legal rights.

Your Legal Rights

Subject to applicable law, you may have a number of rights regarding the Processing of your Personal Data, including:

the right to request access to, or copies of, your Personal Data that we Process or control;
the right to request rectification of any inaccuracies in your Personal Data that we Process or control;
the right to request, on legitimate grounds:
- erasure of your Personal Data that we Process or control; or
- restriction of Processing of your Personal Data that we Process or control;
the right to object, on legitimate grounds, to the Processing of your Personal Data by us or on our behalf;
the right to have your Personal Data that we Process or control transferred to another Controller, to the extent applicable;
where we Process your Personal Data on the basis of your consent, the right to withdraw that consent; and
the right to lodge complaints with a Data Protection Authority regarding the Processing of your Personal Data by us or on our behalf.

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please contact us at compliance@versa-networks.com and we will take steps to correct or delete the information or restrict its use, as appropriate. We will respond to your request within a reasonable timeframe. Upon request Versa will provide you with information about whether we hold any of your personal information. If you wish to update your information, request deletion or believe that any personal information we have about you is, has been, or might be used inappropriately.

Non-Personal and Aggregated Information Collected Automatically

When you visit our websites, we log general data, such as your domain name, the name of the Web page from which you entered our websites, which pages you visit on our websites, and how much time you spend on each page. We use this information to monitor use of and improve our websites as well as for internal analysis.

Tracking Technologies

A cookie is a small file that is placed on your device when you visit a website (including our Site). It records information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Data through cookie technology. Versa and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

Minors

Minors under the age of eighteen years old are not eligible to use our Site and we therefore ask that minors do not submit any Personal Data to us, or use any of the services provided on, through or via our Site.

GDPR Compliance

As in compliance with GDPR, the following section outlines our treatment of Personal Data when Versa is a Processor.

If you are a Customer and deemed a Controller of Personal Data (as such terms are defined herein or in the General Data Protection Regulation (EU) 2016/679), in connection with the provision and use of the Versa products or services under a commercial agreement, the respective data processing activities and obligations shall be governed by the terms of the Data Processing Addendum (the “DPA”), which is hereby incorporated by reference into and forms an integral part of this Privacy Policy and the foregoing agreement(s). You may request an executable version of the DPA by sending an email request to your business point of contact or to the email address provided in the “Contact” section of this Privacy Policy.

Versa collects information under the direction of its Customers, and has no direct relationship with the individuals whose personal data it processes. If you are an individual who interacts with Versa’s Customers and would no longer like to be contacted by Versa’s Customers, please contact the Customer that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the commercial or service agreements with our Customers.

Versa acknowledges that you have the right to access your personal information. Versa has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to Versa’s Customer. If requested to remove data we will respond within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.

Terms of Use

All use of the Site is subject to this Privacy Policy. By accessing or using the Site, you acknowledge and agree to be bound by the terms set forth herein. In addition to this Privacy Policy, your use of the Site, rights and obligations may also be governed by our End User License Agreements (EULAs), and any other applicable legal terms. For more information, please visit the Privacy and/or Legal section of our website, where you can find detailed information on applicable EULAs, additional legal notices and policies. We encourage you to review these documents carefully before using the Site or any related services.

Contact

If you have questions or complaints about this Privacy Policy or want to contact us regarding how we handle your data, please contact us at compliance@versa-networks.com, or write to us at:

Data Protection Officer
Versa Networks, Inc.
2550 Great America Way, Suite 350,
Santa Clara, CA 95054

If you have a question or complaint about this Privacy Policy or our information collection practices, please contact us at compliance@versa-networks.com or write us at the address listed above. We will investigate the matter and are committed to resolve any privacy concerns that you may have.

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