Vemo, Inc. and any of its subsidiaries and affiliates ("Vemo" or "we") respect your preferences concerning the treatment of personal data or information that we may collect from you. This policy lets you know how we collect and use personal information, and how you can control its use. This policy describes the broadest potential use of personal information throughout the Vemo Web sites and in off-line transactions. We may make far less use of personal information than we have outlined in this policy.
EU-U.S. AND SWISS-U.S. PRIVACY SHIELD FRAMEWORK
In compliance with the Privacy Shield Principles, Vemo, Inc. commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Private Shield policy should first contact Vemo, Inc. at: email@example.com
Vemo, Inc. has further committed to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources and/or Non-HR data transferred from the EU and Switzerland in the context of the employment relationship. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs and the Swiss FDPIC are provided at no cost to you.
Vemo, Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
In the context of an onward transfer, a Privacy Shield organization has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Vemo, Inc. shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.
TYPES OF PERSONAL DATA WE COLLECT AND HOW WE COLLECT
This policy covers the following personal information that Vemo collects from its customers through its various operations. Such information may include the following related to employees and contractors of our customers:
Employer, position, length of service, compensation,
Physical address, telephone number and email address,
Birth date or age,
Gender and ethnicity.
USE AND SHARING OF PERSONAL INFORMATION
Vemo uses (and, where specified, shares) personal data for the following purposes:
To Provide Services Requested By Customer. Personal data will be accessed as required to fulfill the requirements of our customer contracts or subsequent requests for service by our customers.
To Maintain and Upgrade the System. We may require periodic access to personal data to monitor our system performance, test systems and develop and implement upgrades to systems. Any temporary copies of personal data created as a necessary part of this process are only maintained for periods of time relevant to those purposes.
To Address Performance and Fix Issues. On occasion, patches and other fixes to software, such as security patches addressing newly discovered vulnerabilities, are developed by Vemo. In accordance with the terms of our customer contracts and/or with notice to you, we may access your test and development or production environment, including personal data, to validate that such patches and fixes work in your environment(s).
To Aggregate Non-Personally Identifiable Data. Vemo may access personal data in order to aggregate non-personally identifiable data across our customer base. While we currently do not disclose any personally identifiable data or aggregated non-personally identifiable data to third parties, in the future, we may provide aggregated data to third parties for purposes other than to provide services to those customers who provided the underlying personal data. Notwithstanding the foregoing, any of our customers may restrict our use of their personal data for this purpose.
As a Result of Legal Requirements. Vemo may be required to provide personally identifiable information to comply with legally mandated reporting, disclosure or other legal process requirements.
Please note that your personal information may be transferred, accessed and stored globally as necessary for the uses stated above in accordance with this policy, provided that before disclosing any personal information to a third party we will either confirm that such third party is subject to the Privacy Shield requirements or has agreed in writing to provide at least the same level of privacy protection as such requirements.
LEGALLY COMPELLED DISCLOSURES
Vemo may disclose your Personal Information if required to do so by law or subpoena or if we believe that such action is necessary to (a) conform to law applicable to us, our group or out partners, comply with a judicial or court order or comply with legal processes served on us or Affiliated Parties; (b) protect and defend our rights and property, our services, the users of the services and/or our Affiliated Parties; or (c) act under circumstances to protect the safety of users of our services, ourselves, or third parties.
COMMUNICATION PREFERENCES AND OPT-OUT
We give all of our customers the right to opt-out on behalf of all or some of their employees and contractors with respect to the non-personally identifiable aggregation of their personal data, as well as opt-out whether personal information will be disclosed to a third party or used for a purpose incompatible with the purpose for which it was originally collected or subsequently authorized.
ACCESS AND PROFILE UPDATES
Vemo may access the customer's hosted environment to provide the necessary support, to resolve an issue or inquiries into performance-related issues, or for periodic maintenance and management of the systems. Vemo also may require that the customers provide access to user information to validate that a particular issue has been resolved. All access to the customer's system is controlled via an access control list (ACL) mechanism, as well as the use of an account management framework, to ensure security at the system and user level. Subject to any requirements of Privacy Shield, access by individual data owners to the personal data provided by our customers is controlled by our customers, and individual data owners should direct any requests for correction, amendment or deletion of personal information to the customer that provided such data to us. Further, for any use or disclosure to a third party by us of sensitive personal data for a purpose other than its original purpose or the purpose authorized subsequently, an affirmative or explicit (opt-in) choice will be offered for such use or disclosure of such data.
The security of personal data is very important to Vemo. We have in place physical, administrative and technical safeguards designed to protect personal information from unauthorized access, disclosure, alteration or destruction. In addition, Vemo uses standard security protocols and mechanisms to exchange the transmission of sensitive data.
In the event that personal data provided by you is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable law requires notification, Vemo will notify you of the breach by email or fax or, if Vemo is unable to contact you by email or fax, then by U.S. mail. Vemo will give you notice promptly, consistent with the reasonable needs of law enforcement and/or Vemo to determine the scope of the breach and to investigate and restore the integrity of the data system.
We rely on our customers in order to ensure that its employees’ and contractors’ personal data is reliable, accurate, complete and current.
If you believe personal data has been used in a way that is not consistent with this policy, you have any complaints or concerns about our use of personal data, or you have further questions related to this policy or our use and disclosure of personal data, please contact Vemo Legal Department by email at firstname.lastname@example.org. Written inquiries may be addressed to Legal Department c/o Vemo, Inc. at 3525 Del Mar Heights Road, #663, San Diego, CA 92130 USA.
In order to ensure our compliance with the Privacy Shield principals, we will make available an appropriate independent recourse mechanism for any unresolved bona fide complaint regarding personal data.
Under certain conditions, you as an individual may invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. To learn more about your right to binding arbitration, please see Section C of Annex I to the Privacy Shield Principles: https://www.privacyshield.gov/article?id=ANNEX-I-introduction
We may update this policy from time to time. We will post a prominent notice in this section of this policy notifying users when it is updated.
Date Created: August 6, 2008
Last Updated: February 25, 2019. To see the prior version of this policy, please request a copy thereof from us.
Vemo's corporate headquarters are located at 3525 Del Mar Heights Road, #663, San Diego, CA 92130 USA.