Privacy Policy

 

Privacy Policy

September 19, 2017

Vera, Privacy Policy: Vera Security, Inc. (“Vera”) considers your privacy paramount, and we take great care in keeping the information of our users private and secure. This Privacy Policy describes our policies and procedures regarding the information that we collect when you use our services, software and website (the “Services”), as well as how we use, disclose, protect and share your information. This Privacy Policy does not apply to third party services that are not under Vera’s control; those parties’ services are governed by their own privacy policies.

We encourage you to read this Privacy Policy carefully as it will help you to make informed decisions about sharing your personal information with us.

Please keep in mind when reading this Privacy Policy that the Vera Services do not store content. Your files are always in your control. Vera provides a security service that will encrypt and protect content, but we do not store the content itself. This Privacy Policy outlines how we protect meta data about your content and your interactions with Vera’s services.

Types of Personal Information Collected
We may collect personal information from users in a variety of ways, including, but not limited to, when you visit our website, place an order, and in connection with other activities, services, features or resources we make available through the Services.

(a) Information collected through our software and services

Vera develops and operates cutting-edge data security solutions that aim to give enterprises complete control of their digital information.

If you request information about our software or services, we’ll collect information that identifies you so that we can respond to your request. Likewise, in the course of subscribing to our software and services, we’ll collect personal information so that we can fulfill your subscription and provide you with any related service support. This means you may need to upload certain information about yourself – for example, items from registrations and transactions (such as name, title, address, company, phone number and e-mail address) and financial/transaction information (such as credit card, card verification value (cvv), and payment information). We will also keep copies of any communications you have with us.

Also, in the course of using our software and services, our subscribers may set certain policies and rules about how others can access and use their files. In such cases, Vera may need to process certain information on behalf of our subscribers about your use of those files and other data for the purpose of delivering the Vera software and services – for example, email addresses, passwords, filenames, and audit trail information of file access including date/timestamps, the user that accesses a file, IP addresses of the user, file forwarding activity, and changes to the file security profile. However, Vera never stores the content of the files themselves – we only store information about the policies surrounding what users can do with those files.

When such information is collected, we are acting on behalf of customers who have subscribed to our software and services and it is the customer, not Vera, that sets the policies surrounding how other users can access and use those files. If you do not want this information about your use of files to be collected, please contact the customer directly.

(b) Information collected through our website and other means

We may also collect information about you when you visit our website (such as electronic communications protocols, IP addresses, web pages visited on our website, and your user preferences), or when you correspond with us by post, email or telephone.

We also collect device specific information, such as hardware model, operating system version, advertising identifiers, unique device identifiers, browser type and language preferences.

Like many businesses, we also collect information through cookies and similar technologies for functionality, analytics and targeted advertising purposes. You can find out more about this in the ‘Cookies’ section below.

Purposes
When you provide personal information to us through our software and services, we use it primarily to deliver our Services to you.

We also collect and use personal information for the following purposes:

  • To develop, operate, improve, deliver, maintain and protect our Services,
  • to communicate with you
  • to market our products and services (where this is in accordance with your marketing preferences),
  • to customize the content we show you, including ads
  • to enhance the safety and security of our Services
  • to collect and handle feedback,
  • to improve customer service,
  • to comply with applicable laws and legal processes,
  • to enforce our terms and conditions and other usage policies,
  • to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others, and to allow us to pursue available remedies or limit any damages that we may sustain.

Disclosures
Vera may disclose information to the following types of third parties:

  • Business partners, trusted affiliates and advertisers, Vera may disclose generic aggregated demographic information not linked to any personal identification information regarding visitors and users.
  • Third party service providers, Vera may share personal information for the purpose of operating or administering the Services, such as sending out newsletters, surveys, or implementing marketing campaigns.
  • Law Enforcement, as we believe to be necessary or appropriate, we may disclose personal information: (a) under applicable laws, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence, including to meet national security or law enforcement requirements; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
  • Others, Vera may disclose personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

When disclosing personal information from the EU and Switzerland to third parties outside of the EU or Switzerland, Vera will enter into a written agreement with such third party that provides adequate protection for the data (for example, by requiring that the third party provide at least the same level of privacy protection as is required by the Privacy Shield Principles).

Under the Privacy Shield, we remain liable if our third party agents process your personal information in a manner inconsistent with the Shield’s Principles, unless we prove that we are not responsible for the event giving rise to the damage.

EU-US and Swiss-US Privacy Shield Framework
Vera’s servers are located in the USA. If you are a non-US resident, this will mean that your personal information will be transferred to the US.

Vera complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Vera has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, Vera commits to resolve complaints about your privacy and our collection or use of your personal information.  European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Vera at: [email protected] or at the address given in the Contact Vera section below.

Vera has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, the complaint may be referred to the US Department of Commerce or Federal Trade Commission for further investigation.

Under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. For further information about the Privacy Shield arbitration scheme, please see https://www.privacyshield.gov/article?id=ANNEX-I-introduction

Vera is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

 

Retention of Personal Information
Vera has the right, but not the obligation, to retain and use such information stored in our databases and other information obtained from your current or previous interactions with the Services for a reasonable period of time, not exceeding any legal requirements or limitations, to resolve disputes, troubleshoot problems and enforce Vera’s rights and the terms and conditions of this Privacy Policy.

Security
Vera implements advanced security to safeguard the privacy of transmissions over public networks. Vera hosts the Services in a secure environment using preventive, detective and corrective technology and processes to safeguard information from attackers. Vera requires unique user names and passwords that must be entered each time a customer logs on. These safeguards help prevent unauthorized access, maintain data accuracy and ensure the appropriate use of data.

The security of your personal information is important to us. We encrypt any information entered within the platform once users are logged into their accounts. We also encrypt all communications between the Vera client and our web services. If you have any questions about security on our Web site, you can contact us at [email protected]

Please keep in mind that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to or from our site is at your own risk. You should only access our website and Services within a secure environment.

How we protect your information
Vera utilizes commercially reasonable measures to prevent unauthorized access to personal information. These measures include policies, procedures, employee training, physical access and technical elements relating to data access controls. In addition, we use standard security protocols and mechanisms to facilitate the exchange and the transmission of sensitive data, such as credit card details. We do not process personal information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the individual. Vera utilizes commercially reasonable measures to prevent unauthorized access to personal information. These measures include policies, procedures, employee training, physical access and technical elements relating to data access controls. In addition, we use standard security protocols and mechanisms to facilitate the exchange and the transmission of sensitive data, such as credit card details. We do not process personal information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the individual.

Marketing Choices
Vera provides you with choices about the use and disclosure of personal information for marketing purposes.

Where it is in accordance with your marketing preferences, we may send you marketing emails regarding our products and services, upcoming promotions and other information that may be of interest to you.

If you do not wish to receive such marketing emails from us, you may use the unsubscribe option at the bottom of our emails to opt out.

From time to time, where it is in accordance with your preferences, we may share your personal information with certain selected affiliates. If you do not wish that we share your personal information with our affiliates for marketing purposes, you may opt-out by contacting us at [email protected].

Vera will attempt to comply with your request as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related messages from us, we may still send you important administrative messages regarding our Services, from which you cannot opt-out.

Access and Other Rights
We acknowledge the right of EU and Swiss individuals to access their personal data. Where we collect personal information on our own behalf, and not on behalf of our customers, you may at any time request to have incomplete, incorrect, unnecessary or outdated personal information deleted or updated by contacting Vera. We will also grant individuals reasonable access to personal information that we hold about them, though such requests may be subject to a fee specified by applicable law. Please note that by requesting Vera to delete your personal information, we may not be able to provide you the Services you have inquired about or ordered.

Individuals wishing to access, change or no longer desire our Services, may view, correct, update of discontinue the use of our Service or delete it by making the change on the Vera account administrator page or by emailing our Compliance department at [email protected]. Vera will respond to your request to access within 30 days.

We will retain your information for as long as your account is active or as needed to provide you Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Please note that where we are processing personal information on behalf of our customers using our services (see “Personal Information” section above), we are not responsible for their use of the data and cannot control their data collection and privacy practices. Any individual who seeks to access, amend or delete this personal information should direct their query to the customer in question. For example, if you use Vera’s services under a corporate account set up by your employer, you should contact your employer directly.

Changes to this Privacy Policy
Vera may change, modify or update this Privacy Policy at any time. When we do, we will revise the date at the top of this page. If we make any material changes, we will post a prominent notice on our website and/or notify you via email or through the Services. We encourage you to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect.

Contact Vera
If you have any questions about this Privacy Policy, please contact us at:

Vera
Attn: Legal Department
318 Cambridge Avenue
Palo Alto, CA 94306 USA
[email protected]

Cookies Policy
We, and third parties with whom we partner, may use cookies, web beacons, local shared objects (sometimes called “flash cookies”), and similar technology in connection with your use of the Services and third party websites (“Cookies”).

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting or analytical information. Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons and flash cookies, to collect and store information about your use of our services, fraud prevention and for other site operations.

Cookies set by Vera are called “first party cookies”. Cookies set by parties other than Vera are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website (e.g. advertising, interactive content and analytics). The parties that set these third party cookies may be able to recognize your computer both when it visits the website in question and also when it visits certain other websites.

Vera uses first party and third party cookies for several reasons. Some cookies are required for technical reasons in order for our websites to operate, and we refer to these as “essential” or ”strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our websites. For example, aggregate statistics, such as IP addresses, operating systems, browser types and the addresses of any referring websites, and general information about the Services’ traffic patterns and related information are collected for analytical purposes. Vera may link the information stored in cookies to any personal information you submit through online forms while accessing or using the Services.

Third parties serve cookies through our website for advertising and other purposes. This is described in more detail below.

The Vera Website
The specific types of first and third party cookies served through our website and the purposes they perform are described in the table below:

Type of cookie
Essential website cookies: These cookies are strictly necessary to provide you with services available through our website and to use some of its features.

Who serves the cookies
• Vera

How to opt out
Because the cookies are strictly necessary to deliver the website to you, you cannot refuse them. You can block or delete them by changing your browser settings – see below under the heading “How can I control cookies?”

 

Type of cookie
Performance and functionality cookies: These cookies are used to enhance the performance and functionality of our website but are non-essential to their use. However, without these cookies, certain functionality may become unavailable.

Who serves the cookies
• Google Analytics
• Disqus
• AddThis

How to opt out
To refuse these cookies, please follow the instructions below under the heading “How can I control cookies?” Alternatively, please click on the relevant opt out link below:
• Google Analytics: https://tools.google.com/dlpage/gaoptout
• Disqus: https://help.disqus.com/customer/portal/articles/1657951
• Addthis: http://www.addthis.com/privacy/opt-out

 

Type of cookie
Analytics cookies:These cookies collect information that is used in aggregate form to help us understand how our websites are being used or how effective are marketing campaigns are, or to help us customize our websites for you.

Who serves the cookies
• Google Analytics

How to opt out
To refuse these cookies, please follow the instructions below under the heading “How can I control cookies?” Alternatively, please click on the relevant opt out link below:
• Google Analytics: https://tools.google.com/dlpage/gaoptout

 

Type of cookie
Advertising cookies: These cookies are used to make advertising messages more relevant to you and to serve Vera ads to users who have visited the Vera website.

Who serves the cookies
• DoubleClick
• Marketo
• AdRoll
• Twitter

How to opt out
To refuse these cookies, please follow the instructions below under the heading “How can I control cookies?” Alternatively, please click on the relevant opt out link below:
• DoubleClick: https://www.google.com/settings/ads/plugin?hl=en&sig=ACi0TCigvVYAN17ugYRMwQf_InKv4i5GKLPNen5UUD8qFqiWU4vtXR5jsz_uaOHdJqvhufEjezDh-Q13icRRRab9WJDGpQbwkQ
• Marketo: http://www.marketo.com/trust/legal/privacy/AdRoll:https://app.adroll.com/optout/safari
• Twitter: https://support.twitter.com/articles/20170514

Please note that the table above describes the cookies that are served on the Vera public website as of September 19, 2017.

The Vera Web Portal
Management of a customer’s tenant is performed through the Vera web portal. When interacting with the web portal, the cookies served are purely functional and include cookies from MixPanel to provide application analytics, Google to provide Google Maps capability, and Amazon Web Services CloudFront Cookies, which are used  to deliver content that a user has downloaded. To refuse these cookies, please follow the instructions below under the heading “How can I control cookies?”

How can I control cookies?
You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by clicking on the appropriate opt-out links provided in the cookie table above. Alternatively, you can set or amend your web browser controls to accept or refuse cookies. The links below will take you to the ‘Help’ sections for some of the major browsers so that you can find out more about how to manage your cookies:

If you choose to reject cookies, you may still use our website and web portal though your access to some functionality and areas of the sites may be restricted. You should be aware that any preferences will be lost if you delete cookies.

Do Not Track
We support Do Not Track. Users can therefore set their browser privacy settings to “Do Not Track” to opt out of tracking. For details about Do Not Track, and how to turn on the setting, visit: http://donottrack.us/