Effective: August 1, 2023
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
2. WHAT INFORMATION DO WE USE?
We will collect and process the following data about you:
2.1 Information you give us about you. This is information about you that you give us by filling in forms on our website (https://www.verifiable.com/) which you may access directly or through another website, or by corresponding with us by e-mail or otherwise. It only includes basic personal data required for you to be able to use our site, subscribe to our service, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our website. The information you give us may include the following information:
- Full name
- Email address(es)
- License or certification data that is made publicly available on government or other websites
- Information that may be provided by you through our customer support email, chat, via social media websites or other third-party platforms where we communicate with users. This may include feedback, contact information, identifying information to assist with finding an account, or any other information provided in these interactions.
2.3 Information we collect about you. With regard to each of your visits to our website, certain information may be automatically collected and stored about your usage:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information, methods used to browse away from the page, and any email used to contact our customer service;
2.4 Information we receive from other sources. This is information we receive about you if you use any other applications we operate or the other services we provide. We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers, search information providers, credit reference agencies).
2.5 Posting and uploading. We collect personal data from you when you provide, post or upload it to our site, such as when you fill out a form, respond to a survey, or submit an API call. You don’t have to post or upload personal data; though if you don’t, it may limit your ability to grow and engage with your network over our Services.
2.6 Publicly available information. We may collect publicly available information that has been publicly disclosed in an official manner by various government, private, or nonprofit organizations, for the purpose of verifying license or certification information. Verifiable will only access, obtain and share this information for the intended purpose for which it has been made available by the issuing organization.
4. HOW DO WE USE THIS INFORMATION?
4.1 We will only use personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing to you directly, at any time by contacting us at firstname.lastname@example.org.
4.2 Information you give to us. We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us, and to provide you with the information and services that you request from us;
- to notify you about important changes to our service.
4.3 Information from an organization. Personal Data received from an Organization will be used in accordance with the Organization's instructions and as required by law in order to fulfill various services to the Organization. Verifiable is a processor of the Personal Data provided by the Organization and the Organization is the controller and is solely responsible for the accuracy, integrity, legality, and completeness of the data provided.
The Personal Data provided by an Organization may be used in combination with information provided by you in order to fulfill the Service on behalf of you or the Organization. This includes:
- Fulfilling Services to an Organization including license verification and monitoring, providing usage or analytics information, and providing account management.
- Enabling Authorized Users to manage Organization accounts which may include tracking your (if you are an Authorized User) name, email, contact information, or relevant billing information to allow you to administer to your account.
- Enforcing our Terms of Service and other policies.
- To investigate and prevent security issues and/or abuse.
- As required by applicable law, legal process or regulation.
- You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here.
4.4 Information we collect about you. We will use this information:
- To administer our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- To improve our website to ensure that content is presented in the most effective manner for you and for your device.
- To allow you to participate in interactive features of our service, when you choose to do so.
- As part of our efforts to keep our website safe and secure.
4.5 Information we receive from other sources. We may receive personal data about you from selected third parties that we work with or that provide us with a service (such as payment services for example) and public sources (such as Companies House for example).
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your contact details and technical data that we collect about you, such as your IP address and the way you browse our website to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (i.e. marketing).
You will receive marketing communications from us if you have requested information from us, purchased goods or services through us, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages to you at any time by following the opt-out links, or by contacting us at any time at email@example.com.
Were you to opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
6. CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email us at firstname.lastname@example.org.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7. HOW DO WE SHARE YOUR INFORMATION?
You acknowledge and agree that from time to time we have the right to share your personal information with:
- An Organization which has previously shared your information with us in order to provide Services. This information will be shared in accordance with an Organization's instructions and in agreement between Verifiable and the Organization, and in compliance with applicable law. This includes Authorized users or other Organization representatives.
- Selected third parties that have been granted access to your Personal data in order to provide Services to you and to the Organization including (a) approved Subprocessors available here (b) select business partners, suppliers and subcontractors for the performance of any contract we enter into with you (c) for the purposes of marketing on behalf of Verifiable.
- Legal authorities or in compliance of legal regulations if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions and other agreements; or to protect the rights, property, or safety of Verifiable, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- Third parties in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets; or if Verifiable or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
9. WHERE DO WE STORE YOUR INFORMATION?
All personal data is processed in the US. For the purposes of IT hosting and maintenance this information is located in the United States. Please contact us at email@example.com if you want further information.
Once we have received your information, we have a data protection process in place to oversee the effective and secure processing of your personal data and we will use strict procedures and security features to try to prevent unauthorized access.
However, and unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website at the transmission stage; any transmission is at your own risk.Verifiable maintains security measures to ensure that data is recoverable and ensures controls are in place for successful completion of backups. Backup systems protect the confidentiality, integrity, and availability of stored data.
Verifiable maintains an access control policy that defines requirements for access and removal of access to Verifiable’s data, systems, facilities, and networks. Administrative access to production servers and databases is restricted based on the principle of least privilege to those team members who have a job function and business need for such access. Verifiable reviews and updates its security policies and plans to maintain organizational security objectives and meet regulatory requirements at least annually.
10. HOW LONG DO WE KEEP YOUR INFORMATION?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. In some circumstances you can ask us to delete your data. See below for further information.
11. WHAT ARE YOUR RIGHTS?
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Right to appeal a decision made by the controller.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
12. EXERCISING YOUR RIGHTS
If you wish to exercise any of your rights set out above, please email us at firstname.lastname@example.org.
We will take reasonable steps to firstly authenticate or verify an individual's request, prior to fulfilling a request for access to personal information.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You will be notified in writing if your request is denied, and the reason for this denial. Should you wish to dispute this, please email email@example.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
13. ADDITIONAL DISCLOSURES FOR U.S. RESIDENTS
Verifiable will comply with any state privacy laws as applicable. This section describes any specific items (not already covered above) pursuant to the following enacted state privacy laws, and only applies to residents of those applicable states:
- California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (CCPA);
- Colorado Privacy Act (CPA)
- Connecticut Data Privacy Act (CDPA)
- Utah Consumer Privacy Act (UCPA)
- Virginia Consumer Data Protection Act (VCDPA)
13.1 California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (CCPA)
Under California Civil Code Section 1798.83, if you are a resident of California and your business relationship with Verifiable is primarily for personal, family or household purposes, you may request certain data regarding Verifiable's disclosure, if any, of Personal Data to third parties for the third parties' direct marketing. To make such a request, please send an email with your request to firstname.lastname@example.org with "Request for California Privacy Information" in the subject line of your email. You may make such a request once per calendar year. If applicable, we will provide you with a list of the categories of Personal Information disclosed to third parties for their direct marketing during the immediately preceding calendar year, along with the third parties' names and addresses. Not all Personal Information sharing is covered by Section 1798.83.
We do not sell your personal data. So, we do not offer an opt-out to the sale of personal data.
13.2 Utah Consumer Privacy Act (UCPA)
When Verifiable is the controller of personally identifiable information, we shall respond to the consumer without undue delay, but in all cases within 45 days of receipt of the request submitted (this may be extended once by 45 additional days when reasonably necessary). Information provided in response to a consumer request shall be provided by Verifiable free of charge, up to once annually per consumer.
13.3 Virginia Consumer Data Protection Act (VCDPA)
When Verifiable is the controller of personally identifiable information, we shall respond to the consumer without undue delay, but in all cases within 45 days of receipt of the request submitted (this may be extended once by 45 additional days when reasonably necessary). Information provided in response to a consumer request shall be provided by Verifiable free of charge, up to twice annually per consumer.
When in possession of de-identified data we will not attempt to re-identify the data.
We implement security safeguards to protect your data such as HTTPS and regularly monitor our systems for possible vulnerabilities or attacks. Based on the nature of the internet as well as other reasons, we can not guarantee complete security of your Personal Data from being accessed, disclosed, altered or destroyed by breach of our security safeguards. You should take precautions to protect your Personal Data through such means as using a secure password, changing your password often, setting up two-factor authentication on your account, using a secure browser, and logging out when using a shared computer.
15. THIRD-PARTY LINKS
16. PROHIBITED USE BY MINORS
Verifiable is a service meant for adult use only and does not promote the Service to children or intentionally collect information from children under the age of 13. If we learn we have collected personal information from an individual under 13, we will delete that information as quickly as possible. If you believe that an individual under 13 may have provided us personal information in violation of this paragraph, please contact us at email@example.com with “Notice of Underage Person” in the subject line.