PRIVACY POLICY

Veracity takes your privacy extremely seriously and would like to describe how we collect, use and protect your information when you access our website(s), products (e.g., Veracity Learning), and other software applications (collectively, the “Services”) operated by Veracity Technology Consultants, LLC (hereinafter referred to as “Veracity”). It is Veracity’s policy to respect your privacy regarding any information we may collect from you across our Services. When you access and use the Services, you are subject to our Terms of Service.

What This Privacy Policy Covers

This Privacy Policy covers our treatment of personally identifiable information (“Personal Information”) that we gather when you are accessing or using our Services. We gather various types of Personal Information from our users, as explained in more detail below, and we may use this Personal Information in order to make our Services available to you, to contact you, and to better understand how you use the Services. This policy covers the types of Personal Information we collect, purposes of using Personal Information, the legal basis for processing Personal Information, practices for sharing Personal Information, your rights to access your Personal Information, and international transfers of Personal Information.

Information We Collect

Information You Provide
We receive and store any information you knowingly provide to us. We collect email addresses and other contact information that users and correspondents provide to us. We also may preserve records of our correspondence. When you register for an account, we ask for your name, username, and email address. We value the trust that you place in us by providing us your personal information. We will always use your personal information in a way that is fair and worthy of that trust. We will always be transparent with you about the information we collect, what we do with it, with whom we share it and who you should contact if you have any concerns. We may optionally ask for personal information, such as your:
  • Name
  • Email
  • Social media profiles
  • Date of birth
  • Phone/mobile number
  • Home/Mailing address
  • Work address
  • Payment information
In keeping with standard online privacy practices, users should not include any highly sensitive information (such as social security numbers, financial information, or “protected health information” (as that term is defined by the Health Insurance Portability & Accountability Act)) in any emails so that such data does not transfer to our servers (even if only temporarily).

In addition, we collect Personal Information you submit to us, for example by completing a form from our Services. In that case, we may communicate with you, for example by calling you at the phone number you provide, sending you promotional email offers, or emailing you about your use of the Services. Also, we may receive a confirmation when you open an email from us. This confirmation helps enhance our engagement with you and generally improve our Services.

Information Collected Automatically
When you interact with our Services, our servers may automatically log the standard data provided by your web browser. Whenever you interact with our Services, we may automatically receive and record information on our server logs from your browser or device, which may include your IP address, “cookie” information, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. We use cookies to track current session information and to streamline your login process. We do not require permanent cookies. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. We may use this data to customize content and generally to improve the Services. Please refer to our Cookie Policy for more information.

Google Analytics Services
We use Google analytics in order to better understand user engagement with the Services. When a user browses or uses the Services, these third party analytics services may collect the user’s IP address, browser type, and approximate location (based on the IP address). They may also use web logs or web beacons and may set and access cookies on your computer or other device.

Purposes of Using Personal Information

We may collect, hold, use and disclose information for the following purposes and personal information will not be further processed in a manner that is incompatible with these purposes:
  • to enable you to customise or personalise your experience of our website;
  • to enable you to access and use our website, associated applications and associated social media platforms;
  • to contact and communicate with you;
  • for internal record keeping and administrative purposes;
  • for analytics, market research and business development, including to operate and improve our website, associated applications and associated social media platforms;
  • for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you; and
  • to comply with our legal obligations and resolve any disputes that we may have.

Legal Basis for Processing Personal Information

We will process your personal information lawfully, fairly and in a transparent matter. We collect and process information about you only where we have legal basis for doing so.

The legal basis depends on the services you use and how you use them, meaning we collect and use your information only where:
  • it’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when we provide a service you request from us);
  • it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our services, and to protect our legal rights and interests;
  • you give us consent to do so for a specific purpose (for example, you might consent to us sending you our newsletter); or
  • we need to process your data to comply with a legal obligation.
Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).

We don’t keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.

Sharing Personal Information

Except as described in this policy, we will not give, sell, rent or loan any personal information to any third party. Personal information will only be shared as follows:

Agents and vendors
We may employ other companies and people to perform tasks on our behalf and need to share your information with them, including in some cases the Personal Information you have provided to us, in order to make the Services available to you. For example, we may use third party hosting providers or software developers to help implement and maintain the Services. Our Services may be directly accessed through other web applications through an API integration. Personal information that you provide to those sites may be sent to Veracity in order to deliver the service. We process such information under this Privacy Policy. However, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to integrate.

Business Transfers
If we are involved in a reorganization, merger, acquisition or sale of our assets, your information may be transferred as part of that deal. We will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event.

Protection of Veracity and Others
We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order; enforce or apply our applicable terms of use and other agreements; or protect the rights, property, or safety of Veracity, our employees, our users, or others.

Right to Access Personal Data

We acknowledge the right of individuals to access their personal information and data collected by Veracity. Although we own the source code, databases and all rights to Veracity Learning, you retain all rights to your data. We implement security measures to protect your information from loss, destruction, misuse, unauthorized access or disclosure. These practices help ensure that your data is safe, secure, and only accessible to you or other applications where you approved access. However, no data transmission over the internet or information storage can be guaranteed to be 100 percent secure. Requests to access personal information or data should be submitted to privacy@veracity, with the subject line “Personal Data Request.” Additional details about your access rights and controlling your personal information are provided below.

Choice and consent
By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this privacy policy. If you are under 16 years of age, you must have, and warrant to the extent permitted by law to us, that you have your parent or legal guardian’s permission to access and use the website and they (your parents or guardian) have consented to you providing us with your personal information. We do not knowingly collect personal information from children without the consent of the child's parent or guardian. You do not have to provide personal information to us, however, if you do not, it may affect your use of this website or the products and/or services offered on or through it.

Information from third parties
If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict
You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us at privacy@veracity.it. If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our products and services.

Access and data portability
You may request details of the personal information that we hold about you. You may request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal information we hold about you at any time.

Correction
If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Notification of data breaches
In the case of a personal data breach, Veracity shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to a Veracity supervisory authority. Where the notification to the supervisory authority is not made within 72 hours, it shall be accompanied by reasons for the delay. When the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, Veracity shall communicate the personal data breach to the data subjects without undue delay.

Complaints
If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also may the right to contact a regulatory body or data protection authority in relation to your complaint.

Unsubscribe
To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us at contact@veracity.it or opt-out using the opt-out mechanisms provided in the e-mail message or website.


International Transfers of Personal Information

The personal information we collect is stored and processed where we or our server hosting partners, affiliates and other third-party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these third parties.


Changes to This Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but if we do, we will bring it to your attention by placing a notice on our website, https://veracity.it/privacy-policy and/or by sending you an email, and/or by some other means. Your use of the Services after any changes to the Privacy Policy have been posted will be considered to indicate your acceptance of the changes.

Your continued use of this site after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information.

If we make a significant change to this privacy policy, for example changing a lawful basis on which we process your personal information, we will ask you to re-consent to the amended privacy policy.

This policy is effective as of 19 June 2018.


Questions About Our Privacy Policy

If you have any questions, concerns, or complaints regarding our privacy policies, please don’t hesitate to contact us, and we will work hard to resolve your concerns.

This policy is effective as of 19 June 2018.