Last updated: May 5, 2021
1. Overview and Scope
This policy and supporting procedures cover the privacy of all data collected by Vesta Innovations in its interaction with individuals in its business operations.
2. Roles and Responsibilities
The following roles and responsibilities are to be developed and subsequently assigned to authorized personnel within Vesta Innovations regarding privacy practices:
Chief Privacy Officer: Responsibilities include providing overall direction, guidance, leadership, and support on methods and tools for the implementation of a security and privacy-related program. The Chief Privacy Officer will conduct resource and investment planning to implement the management, operational, technical, and privacy requirements of the program.
Privacy Committee: Responsibilities include approving and monitoring adherence to this policy, analyzing the organization’s environment, and the legal requirements with which it must comply. Additional responsibilities include:
Execute the privacy operations of the firm, including monitoring the system used to solicit, evaluate, and respond to individual privacy complaints and problems.
Evaluate implemented privacy controls;
Assessing existing policies and procedures that address privacy areas;
Working with appropriate departments to ensure compliance with privacy policies and procedures;
Recommending and monitoring, in conjunction with the relevant departments, the development of internal systems and controls to carry out the organization’s privacy objectives;
Report to the Chief Privacy Officer on the effectiveness of the privacy controls/program in meeting applicable regulatory requirements and standards.
3. Personal Information
"Personal Information," as used in this policy, is information that specifically identifies an individual, such as an individual’s name, social security number, telephone number, or e-mail address. Personal information also includes information about an individual’s activities, such as information about his or her activity on the Site or credit history, and demographic information, such as date of birth, gender, address, geographic area, and preferences, when any of this information is linked to personal information that identifies that individual. Personal information does not include "aggregate" or other non-personally identifiable information. Aggregate information is information that we collect about a group or category of products, services, or users that is not personally identifiable or from which individual identities are removed. We may use and disclose aggregate information, and other non-personally identifiable information, for various purposes.
4. Collection of Information
4.1 Passive Information Collection
When you use the Service, some information may be automatically collected, such as your IP address, browser type, system type, the content and pages that you access on the Site, "referring URL" (i.e., the page from which you navigated to the Site), the pages you navigate to on the Site, and from which you leave the Site, as well as the time you spend on the Site.
We collect this information passively using technologies such as standard server logs, cookies, and clear GIFs (also known as "Web beacons"). We use passively collected information to administer, operate, and improve the Site and our other services and systems, and to provide services and content that are tailored to you. If we link or associate any information gathered through passive means with personal information, we treat the combined information as personal information under this policy. Otherwise, we use information collected by passive means in a non-personally identifiable form only.
Also, please be aware that third parties may set cookies on your hard drive or use other means of passively collecting information about your use of their services or content. We do not have access to, or control over, these third-party means of passive data collection.
4.2 Collection of Voluntarily Provided Information
We may collect personal information that our users provide to us in a variety of ways through our Service. For instance, when you request information about our services or otherwise communicate with us, we collect the personal information that is provided to us. We may collect personal information such as name, e-mail address, city, state, country, other demographic information, and your interests and preferences in these manners.
4.3 Information from Other Sources
We may receive information about you, including personal information, from third parties, and may combine this information with other personal information we maintain about you. If we do so, this policy governs any combined information that we keep in a personally-identifiable format.
5. Use of Personal Information
We use personal information to provide services and information that you request; to enhance, improve, operate, and maintain the Site and Service, our programs, services, website, and other systems; to prevent fraudulent use of our Site and Service; to tailor your user experience; to maintain a record of our dealings with you, and for other administrative purposes.
We may also use the personal information you provide to contact you regarding our products and services. We allow you to opt-out from receiving marketing communications from us as described in the "Choice" section below.
6. Disclosure of Personal Information
We will not disclose your personal information to third parties without your consent, other than as described in this policy. We may disclose personal information to third party service providers (e.g., data storage and processing facilities) that assist us in our work. We limit the personal information provided to these service providers to that which is reasonably necessary for them to perform their functions.
We may also disclose personal information if we believe that doing so is legally required or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others.
In addition, information about our users, including personal information, may be disclosed as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information could be transferred to third parties as one of our business assets.
If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial email from us by sending us an email or by writing to us at the address given at the end of this policy.
For your convenience, the Site may contain links to other Web sites, products, or services that we do not own or operate. If you choose to visit or use any third-party products or services, please be aware that this policy will not apply to your activities or any information you disclose while using third-party products or services or otherwise interacting with third parties.
Children’s safety is important to us, and we encourage parents and guardians to take an active interest in the online activities of their children. We do not knowingly collect personal information from children under the age of 13 without obtaining parental consent.
10. International Visitors
Our Site and Service is hosted in the United States and is generally intended for United States visitors. If you visit from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please be aware that you are transferring personal information to the United States. The United States does not have the same data protection laws as the European Union and some other regions. By providing personal information to us, you consent to the transfer of it to the United States and the use of it in accordance with this policy.
Vesta Innovations protects the Personal Information it collects with reasonable and appropriate physical, electronic, and procedural safeguards. We use reasonable security measures that are designed to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please note, however, that no data security measures can be guaranteed to be completely effective. Consequently, we cannot ensure or warrant the security of any personal information or other information. You transmit information to us at your own risk.
12. Updates to this Policy
We may occasionally update this Policy. When we do, we will also revise the "last updated" date at the beginning of the policy. Your continued use of this Service after such changes will be subject to the then-current policy. We encourage you to periodically review this policy to stay informed about how we collect, use, and disclose personal information.
13. Contacting Us
14. Policy Administration
14.1 Ownership and Review
The Policy Owner owns this Policy and is responsible for reviewing the Policy for updates annually, or following major changes to Vesta Innovations’s compliance environment. The Policy Approver retains approving authority over this Policy.
14.2 Monitoring and Enforcement
Vesta Innovations periodically monitors adherence to this Policy to help ensure compliance with applicable laws, requirements, and contractual agreements that apply to Client & Consumer Data. Vesta Innovations may also establish enforcement mechanisms, including disciplinary actions, to help ensure compliance with this Policy.