Privacy Policy

Last modified: May 10, 2019

1. Introduction
This Privacy Policy describes how Verodin collects and uses Personal Data about you through our Services, Products, and Websites, mobile applications, and through email, text, and other electronic communications between you and Verodin.
Verodin, Inc. (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.
This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the websites including www.verodin.com (our “Websites”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:     
-On our Websites.
-In email, text, and other electronic messages between you and our Websites.     
-Through mobile and desktop applications.
It does not apply to information collected by:     
-us offline or through any other means, including on any other website operated by Verodin or any third party (including our affiliates and subsidiaries); or      
-any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Websites. By accessing or using these Websites, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Section 15, Changes to Our Privacy Policy). Your continued use of this Websites after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

2. Data Controller, Data Protection Officer, and Representative
Verodin is the data controller of the Personal Data you provide on the Websites.
Verodin is the data controller of your Personal Data. At this time, Verodin is not required to appoint a Data Protection Officer or a representative in the EU, and has elected not to do so. Verodin may be contacted in any manner set forth below in the “Contact Information” Section of this Privacy Policy.

3. Children Under the Age of 18
Our Websites are not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Websites. We will remove any information about a child under the age of 18 if we become aware of it.  
Our Websites are not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Websites. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Websites or on or through any of its features, register on the Websites, or make any purchases through the Websites. If we learn we have collected or received Personal Data from a child under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us using the methods in section 18.

4. Information We Collect About You and How We Collect It
We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.
 
Generally
We collect several types of information from and about users of our Websites, specifically information:       
-by which you may be personally identified, such as name, postal address, e-mail address, telephone number, job title, or clothing size (“Personal Data”) and       
-about your internet connection, the equipment you use to access our Websites and usage details.
We collect this information:·       
-directly from you when you provide it to us.       
-automatically as you navigate through the site.Information collected automatically may include usage details, IP addresses, and information collected through cookies.       
-from third parties, for example, our business partners.

Information You Provide to Us
The information we collect on or through our Websites are:       
-information that you provide by filling in forms on our Websites. This includes information provided at the time of registering to use our Websites, subscribing to our service, or requesting further services. We may also ask you for information when you report a problem with our Websites;      
-records and copies of your correspondence (including email addresses), if you contact us;      
-details of transactions you carry out through our Websites and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website;       
-your search queries on the Website
The Personal Data we collect from you is required to enter into a contract with Verodin, for Verodin to perform under the contract, and to provide you with our products and services. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data, then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it.

Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:       
-details of your visits to our Website, specifically traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.      
-Information about your computer and internet connection, specifically your IP address, operating system, and browser type.
The information we collect automatically is statistical data and does not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Websites and to deliver a better and more personalized service by enabling us to:       
-estimate our audience size and usage patterns;       
-store information about your preferences, allowing us to customize our Websites according to your individual interests;       
-speed up your searches; and       
-recognize you when you return to our Website.
Details about the automated data collection technologies and the specific cookies that we use can be found in our Cookie Policy, located at www.verodin.com/TermsofUse.

5. Lawful Basis for Processing Your Personal Data
We have a lawful basis for our processing of your Personal Data, including processing for our legitimate interests (when balanced against your rights and freedoms), to fulfill our obligations to you under a contract with you, and required by law, and with your consent.  
If you are in the European Union, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies as described below):     
-Consent. By using our Websites, you consent to our collection, use, and sharing of your Personal Data as described in this privacy policy. If you do not consent to this privacy policy, please do not use the Websites;      
-Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your Personal Data if your rights and freedoms outweigh our legitimate interests. Specifically, our legitimate interests are to: facilitate communication between Verodin and you; detect and correct bugs and to improve our Websites; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; promote and market our business; check your credit and perform risk assessments; and develop our product and services;      
-To Fulfill Our Obligations to You under our Contract. We process your Personal Data in order to fulfill our obligations to you pursuant to our Contract with you to deliver our goods and services to you.     
-As Required by Law. We may also process your Personal Data when we are required or permitted to by law; to comply with government inspection, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.

6. How We Use Your Information
We use your Personal Data for various purposes described below, including to:
-provide our Websites to you;       
-provide you with information you request from us;      
-enforce our rights arising from contracts;       
-notify you about changes; and       
-provide you with notices about your account
We use information that we collect about you or that you provide to us, including any PersonalData:       
-to present our Websites and their contents to you.       
-to provide you with information, products, or services that you request from us.       
-to fulfill any other purpose for which you provide it.       
-to provide you with notices about your account, including expiration and renewal notices.       
-to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.       
-to notify you about changes to our Websites or any products or services we offer or provide though them.       
-in any other way we may describe when you provide the information.       
-for any other purpose with your consent.

With your consent, we may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you wish to consent to this use, please check the relevant box located on the form on which we collect your data. If you wish to change your choice, you may do so at any time by logging into the Websites and adjusting our user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request at privacy@verodin.com.

7. Disclosure of Your Information
We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. We disclose your Personal Data to a few third parties, including:       
-our subsidiaries and our affiliates;       
-our third party service providers that we use to support our business;      
-to a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form;      
-to comply with our legal obligations;      
-to enforce our rights; and
-with your consent.
We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose Personal Data that we collect or you provide as described in this privacy policy:       
-To our subsidiaries and affiliates.       
-To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. Specifically, these entities provide IT and infrastructure support services.       
-To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Verodin’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which PersonalData held by Verodin about our Websites’ users is among the assets transferred.
-To fulfill the purpose for which you provide it.      
-For any other purpose disclosed by us when you provide the information.       
-With your consent.

We may also disclose your Personal Data:      
-To comply with any court order, law, or legal process, including to respond to any government or regulatory request.       
-To enforce or apply our Website Terms of Use and other agreements, including for billing and collection purposes.       
-If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Verodin, our customers, or others.

8. Choices About How We Use and Disclose Your Information
We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for third-parties to advertise to you, our advertising to you, and other targeted advertising.
We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes. You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info). We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:
·Tracking Technologies and Advertising. You can set your browser to refuse all orsome browser cookies, or to alert you when cookies are being sent. To learn howyou can manage your Flash cookie settings, visit the Flash player settings pageon Adobe’s website.If you disable or refuse cookies, please note that some parts of this site maythen be inaccessible or not function properly.       
-Disclosure of Your Information for Third-Party Advertising. We will only share your Personal Data with unaffiliated or non-agent third parties for promotional purposes with your express consent. If you wish to consent to such use, you can check the relevant box located on the form on which we collect your Personal Data or otherwise seek such consent. If you wish to change your choice, you may do so at any time by logging into the Websites and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to privacy@verodin.com.       
-Promotional Offers from Verodin. We will only use your email address or contact information to promote our own or third parties’ products and services with your express consent. If you wish to consent to such use, you can check the relevant box located on the form on which we collect your Personal Data or otherwise seek such consent. If you wish to change your choice, you may do so at any time by logging into the Websites and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to privacy@verodin.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Verodin as a result of a product purchase, warranty registration, product service experience or other transactions.

9. Your Rights Regarding Your Information and Accessing and Correcting Your Information
You may have certain rights under applicable data protection laws, including the right to access and update your Personal Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any time, and the right to have us erase certain Personal Data about you. You also have the right to complain to a supervisory authority about our processing of your Personal Data.       
Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data.
-Access and Update. You can review and change your Personal Data by logging into the Websites and visiting your “Account” page. You may also notify us through the contact information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. Please note that if you request access to your Personal Data other than through our Websites, you may be charged a fee subject to a maximum set by applicable law. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
·Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing, but we have retained it as permitted by law.
·Portability. To the extent the Personal Data you provide Verodin is processed based on your consent, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
·Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
·Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We cannot delete your Personal Data except by also deleting your user account, and we will only delete your account when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use at ww.verodin.com/TermsofUse.
-Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.      
-How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods below and through the live chat feature of our Websites. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements.

10. Your California Privacy Rights
Under some circumstances, California law may provide you with the right to obtain a list of third parties (if any) that we provide your Personal Data to for their own direct marketing purposes.
California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Websites that are California residents and who provide Personal Data in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Data to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Data and the names and addresses of those businesses with which we shared your Personal Data with for the immediately prior calendar year (e.g. requests made in 2018 will receive information regarding such activities in 2017). You may request this information once per calendar year. To make such a request, please contact us at any of the methods listed in section 16.

11. Do Not Track Signals
We currently do not honor do-not-track signals that may be sent by some browsers.
Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such signal is broadcast or received.

12. Data Security
Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Websites confidential.
We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

13. Consent to Processing of Personal Data [in the United States/In Other Countries Outside the European Economic Area]
We may process your Personal Data outside of your home country, including to the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Data.
If you are a resident of the European Economic Area (“EEA”), in order to provide our Websites, products, and services to you, we may send and store your Personal Data outside of the EEA, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an adequate level of protection for your Personal Data.Your Personal Data is transferred by Verodin to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. By using our Website, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data that you provide directly to us on our Website. To ensure your Personal Data (other than Personal Data you provide directly to us on our Website) is treated in accordance with this Privacy Policy, Verodin uses Data Protection Agreements between Verodin and all other recipients of your data that include, where applicable, the Standard Contractual Clauses adopted by the European Commission (the “Standard Contractual Clauses”). The European Commission has determined that the transfer of Personal Data pursuant to the Standard Contractual Clauses provides for an adequate level of protection of your Personal Data. Under these Standard Contractual Clauses, you have the same rights as if your data was not transferred to such third party. You may request a copy of the Data Protection Agreement by contacting us through the contact methods below.

14. Data Retention Periods
We retain your Personal Data for as long as you keep your account open. In some instances, we may keep it after you close your account, for example we may keep it:       
-for as long as necessary to comply with any legal requirement;
-on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;     
-for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and    
-for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.

15. Changes to Our Privacy Policy
We will post any changes to our Privacy Policy on our Websites. If we make material changes to our Privacy Policy, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.
We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Websites and this Privacy Policy to check for any changes.

16. Contact Information
You may contact Verodin through the contact information below. If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you must contact us at the contact information below or through the “Contact” page on our Website.

To Contact Verodin
Verodin
8200 Greensboro Drive, Suite #1400
McLean, VA 22102
privacy@verodin.com
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