Valeyo, a division of Perseus Group Software Corp. (“Company,” “Us,” “Our,” or “We”) respects Your privacy and is committed to protecting it through Our compliance with this Privacy Policy. Please read this Privacy Policy carefully to understand Our policies and practices regarding the Personal Information We collect from You, how We use it, how We share it, Your rights and choices with respect to Your Personal Information, and how You can contact Us about Our privacy practices.
This Privacy Policy applies to Personal Information We collect about You from various sources, as further described in the “Personal Information We Collect and How We Collect It” section below.
“Affiliate” means any entity that now or hereafter (i) directly or indirectly owns or controls, is owned or controlled by, or is under common ownership or control with Us, and (ii) is under common management with Us.
“B2B Party” means a Vendor or business partner (any of which can be a sole proprietorship or a formal legal entity) with whom We have a business relationship and who directly or indirectly provides Us with B2B Representative and/or End User Personal Information in connection with those B2B Representatives’ or End Users’ use of Our Products or otherwise.
“B2B Representative” refers to individuals who work for or on behalf of a B2B Party, or in the event that the B2B Party is a sole proprietorship, the B2B Representative is the sole proprietor.
“End User” means individuals who do business with, or otherwise interact with, a B2B Party but who are not doing business with Us directly.
“Personal Information” means any information that identifies or relates to an individual or can be used in conjunction with other information to identify an individual, whether such information is explicitly regulated by applicable law or otherwise.
“Processing” means any operation or set of operations which is performed on Personal Information, encompassing the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction or erasure of Personal Information. The terms “Process”, “Processes” and “Processed” will be construed accordingly.
“Product(s)” means the products and services that We offer, including, but not limited to, software, software-as-a-service, support/maintenance, professional services, and hosting services.
“Vendor” means an individual or legal entity that is hired by Us to Processes Your Personal Information on Our behalf.
“Visitor” means (i) any individual that visits the Website, including a B2B Representative or End User, provided that a B2B Representative or End User that visits the Website shall only be deemed a Visitor with respect to their activities while visiting the Website, or (ii) anyone that otherwise communicates with the Company that is not a B2B Representative or End User.
“Website” means any publicly accessible website hosted by or on behalf of the Company which is not part of a Product.
“You” and “Your” mean B2B Party, B2B Representative, End User, or Visitor, depending on the context as further explained in this Privacy Policy, and if there is no context which specifically identifies any of the foregoing, then “You” or “Your” means all of the foregoing collectively.
Generally speaking and without regard to any particular definition under applicable law, We are a data processor (“Processor”) when We do not determine the purpose and means of Processing the Personal Information of B2B Representatives and End Users, and We only Process that Personal Information in accordance with the specific instructions of a B2B Party, as is the case when We Process Personal Information only as necessary to provide Our Products to a B2B Party. We receive instructions from B2B Parties through agreements We have with those B2B Parties, including any ancillary data privacy agreements or addenda (collectively a “B2B Agreement”). This Privacy Policy does not apply when We Process Personal Information as a Processor.
When You are a B2B Party and We act as a Processor with respect to the Personal Information that We receive from You or on Your behalf, You alone are responsible for providing appropriate privacy notices and disclosures to Your B2B Representatives and End Users with respect to Your Processing of their Personal Information. You cannot rely on this Privacy Policy as a means for satisfying Your privacy notice and disclosure obligations.
When You are a B2B Representative or an End User and We act as a Processor with respect to Your Personal Information, the B2B Party with whom You have a relationship is responsible for providing appropriate notices and disclosures to You about how they Process Your Personal Information and You must refer to that B2B Party’s privacy policy or other notices for information regarding their privacy practices, Your rights, and how You exercise those rights.
Generally speaking and without regard to any particular definition under applicable law, We are a data controller (“Controller”) when We determine the purpose and means of Processing the Personal Information of B2B Representatives and End Users, as is the case when a B2B Party permits Us to Process that Personal Information in ways that relate to Our Products but are not strictly necessary in order to perform those Products. This Privacy Policy only applies when We Process Personal Information as a Controller.
When You are a B2B Party and We act as a Controller with respect to the Personal Information that We receive from You or on Your behalf pursuant to a B2B Agreement, We are responsible for providing appropriate privacy notices and disclosures to Your B2B Representatives and End Users with respect to Our Processing of their Personal Information as a Controller. However, pursuant to the B2B Agreement, You agree to comply with all applicable laws, including those which may require You to provide notice to or gain consent from Your B2B Representatives and End Users prior to giving Us permission to Process that Personal Information as a Controller. Specifically, You and Your legal advisors should consider whether You need to list Us in Your privacy policy and notify Your End Users of Our privacy practices by linking to this Privacy Policy.
When You are a B2B Representative or an End User and We act as a Controller with respect to Your Personal Information (to the extent that We Process any such Personal Information), this Privacy Policy describes Our privacy practices, including the Personal Information We collect from You, how We use it, how We share it, Your rights and choices, and how You can contact Us about Our privacy practices. However, as mentioned in the “Our Role as a Processor” section above, You must refer to the privacy notices and disclosures of the B2B Party with whom You have a relationship for more information regarding that B2B Party’s privacy practices, including any notices or disclosures with respect to that B2B Party’s transfer of Your Personal Information to Us for Our Processing as a Controller. When You are a Visitor, We are a Controller with respect to Your Personal Information. We Process Your Personal Information in accordance with this Privacy Policy and any other agreement We may have directly with You. This Privacy Policy describes Our privacy practices, including the Personal Information We collect from You, how We use it, how We share it, Your rights and choices, and how You can contact Us about Our privacy practices.
(subject to applicable law, where stated)
| Categories and Types of Personal Information We Collect | Sources From Which We Collect Your Personal Information |
| Identifiers, including real name, postal address, phone number, Internet Protocol address, email address, and account ID |
|
| Sensory Data, including audio and visual information | |
| Professional or employment-related information, including job title and place of employment |
For End Users
We are not a Controller with respect to any End User Personal Information.
For Visitors
When You are a Visitor, We collect the following Personal Information about You from the following sources:
| Categories and Types of Personal Information | Sources From Which We Collect Your Personal Information |
| Identifiers, including real name, postal address, phone number, Internet Protocol address, and email address |
|
| Commercial Information, including records of Products considered | |
| Internet or other similar network activity, including browsing history; search history; and information on Your interaction with Our Website | |
| Geolocation data, including imprecise physical location derived from IP address and/or wifi networks | |
| Sensory data, including audio and visual information | |
| Professional or employment-related information, including job title and place of employment |
For B2B Representatives
When You are a B2B Representative, We Process Your Personal Information described below for the following purposes and based on the following legal bases:
| Categories and Types of Personal Information We Collect | Sources From Which We Collect Your Personal Information |
| Identifiers, including real name, postal address, phone number, Internet Protocol address, email address, and account ID |
|
| Sensory Data, including audio and visual information |
|
| Professional or employment-related information, including job title and place of employment |
|
When You are a B2B Representative, We disclose Your Personal Information described below to the following categories of third-parties and for the following purposes:
| Categories and Types of Personal Information | Categories of Parties to Whom We Disclose the Information | Purpose for Disclosing |
| Identifiers, including real name, postal address, phone number, Internet Protocol address, email address, and account ID | Vendors |
|
| Visitors |
| |
| Sensory Data, including audio and visual information | Vendors |
|
| Visitors |
| |
| Professional or employment-related information, including job title and place of employment | Vendors |
|
| Visitors |
|
For End Users
We are not a Controller with respect to any End User Personal Information.
For Visitors
When You are a Visitor, We Process Your Personal Information described below for the following purposes and based on the following legal bases:
| Categories and Types of Personal Information | Purpose for Processing |
| Identifiers, including real name, postal address, phone number, Internet Protocol address, and email address |
|
| Commercial Information, including records of Products considered |
|
| Internet or other similar network activity, including browsing history; search history; and information on Your interaction with Our Website |
|
| Geolocation data, including imprecise physical location derived from IP address and/or wifi networks |
|
| Sensory Data, including audio and visual information |
|
| Professional or employment-related information, including job title and place of employment |
|
When You are a Visitor, We disclose Your Personal Information described below to the following categories of third-parties and for the following purposes:
| Categories and Types of Personal Information | Categories of Parties to Whom We Disclose the Information | Purpose for Disclosing |
| Identifiers, including real name, postal address, phone number, Internet Protocol address, email address, and account ID | Vendors |
|
| Visitors |
| |
| Internet or other similar network activity, including browsing history; search history; and information on Your interaction with Our Website | Vendors |
|
| Geolocation data, including imprecise physical location derived from IP address and/or wifi networks | Vendors |
|
| Sensory Data, including audio and visual information | Vendors |
|
| Visitors |
| |
| Professional or employment-related information, including job title and place of employment | Vendors |
|
| Visitors |
|
Aggregated, Deidentified, and Anonymized Data
We create aggregated, deidentified, or anonymized data derived from Our use of Your Personal Information, and such data can be used by Us as permitted by applicable laws and regulations. We will not attempt to re-identify the data.
Other Purposes for Processing and Disclosing Your Personal Information
We may also Process and disclose Your Personal Information:
No telephone or SMS information will be shared with third parties or Affiliates for their own marketing/promotional purposes. All the above disclosures exclude text messaging originator opt-in data and consent, which will not be shared with any third parties. We will only send SMS/telephone communications when We have the appropriate consent to do so or as otherwise permitted by law.
Upon receipt of Your consent, 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, including:
The information We collect automatically does, in some cases, include Personal Information, or We may maintain it or associate it with Personal Information We collect in other ways or receive from third parties. These activities help Us improve Our Website and Products and deliver a better and more personalized experience, including by enabling Us to:
The technologies We use for this automatic data collection may include:
In some cases, You may also block the use of non-essential cookies altogether using cookie management technology available to You when You visit the Website. You may also leverage any of the methods identified in the “Exercising Your Rights” section below in order to opt-out of certain cookies.
Google Cookies and Tracking Technologies
Google Analytics
We use Google Analytics to track information about how You interact with Our Website and Products so that We can make improvements. We also use analytics cookies to test pages, features or new functionality of the Website and Products to see how Our users react to them.
In order to collect this information, Google Analytics may set cookies on Your browser or mobile device, or read cookies that are already there. Google Analytics may also receive information about You from apps You have downloaded, that partner with Google. We do not combine the information collected through the use of Google Analytics with Personal Information. Click https://policies.google.com/technologies/partner-sites to learn about how to control information used by Google Analytics. Google’s ability to use and share information collected by Google Analytics about Your visits to the Website to another application which partners with Google is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Please review those and see https://policies.google.com/privacy or information about how Google uses the information provided to Google Analytics and how You can control the information provided to Google. Please also visit https://tools.google.com/dlpage/gaoptout/ for information about a Google Analytics opt-out browser add-on.
Our Website may contain content from and links to other sites that are operated by third parties that may use cookies. We do not control these third-party sites or cookies and this Privacy Policy does not apply to them. Please consult the terms and conditions and Privacy Policy of the relevant third-party site to find out how that site collects and uses Your information and to establish whether and for what purpose they use those cookies. If You are unclear who the responsible third party is, You can contact Us using any of the methods identified in the “Exercising Your Rights” section below.
In order to carry out the Processing activities described above, We may make use of subcontractors that act on Our behalf as Processors. These subcontractors will be contractually obligated by Us to Process Your Personal Information only in accordance with Our instructions, only for the purposes described above, and only for the period of time necessary to perform those purposes.
In some cases, these subcontractors may be located outside of the data privacy jurisdiction in which You reside. In the event such international data transfers are necessary, We will take the necessary organizational, technical and contractual measures to ensure the protection of Your Personal Information. In certain situations, We may be required to disclose Personal Information in response to lawful requests from law enforcement and national security authorities of that jurisdiction.
For questions or comments about Our practices with respect to international data transfers, please refer to the “Contact Information” section at the end of this Privacy Policy.
Depending on Your location and subject to applicable law and certain other limitations, You may have the rights set forth below with respect to Your Personal Information. To exercise any of the following rights, please refer to the “Exercising Your Rights” section at the end of this Privacy Policy.
Right of Access/Right to Know and Data Portability. You have the right to receive confirmation as to whether or not Your Personal Information is being Processed, and, where that is the case, You have a right to request additional information about the categories of Personal Information collected, sold, disclosed, or shared; purposes for which this Personal Information was collected, sold, disclosed, or shared; categories of sources of Personal Information; and categories of third parties with whom We disclosed or shared this Personal Information. You have a right to receive this information in a portable and, to the extent technically feasible, in a readily useable format that allows You to transmit this information to another entity without hindrance.
Right of Rectification/Correction. You have the right to request that We correct or update Your Personal Information that is inaccurate, incomplete or outdated.
Right to Erasure/Deletion. You have the right to request the deletion of Your Personal Information in certain circumstances (but only where they are no longer required for a legitimate business purpose or required by law).
Right to Opt-Out of Direct Marketing and Targeted Advertising. To the extent that We Process Your Personal Information for the purposes of direct marketing or targeted advertising (as those terms are defined by the applicable laws of the jurisdiction in which You reside, but which generally means the display of an advertisement to You based on Personal Information about You obtained or inferred over time from Your activities across nonaffiliate websites, applications, or online applications), or to the extent that We provide Your Personal Information to others for those purposes, You have the right to opt-out of that activity.
Right to Opt-Out of the Sale of Personal Information. To the extent that We sell Your Personal Information (as that term is defined by the applicable laws of the jurisdiction in which You reside), You have the right to opt-out of that activity.
Right to Opt-Out of Automated Profiling. You have a right to opt out of any automated Processing of Your Personal Information, including for profiling purposes (as those terms are defined by the applicable laws of the jurisdiction in which You reside, and subject), but only to the extent that such Processing activities are used to make decisions which produce legal effects, or similarly significant effects, that affect You.
Right to Restrict Processing. You have the right to restrict the Processing of Your Personal Information in certain circumstances, such as when We consider another request that You have submitted.
Right to Object. In certain circumstances, You have the right to object to the Processing of Your Personal Information where the Processing is necessary for performance of a task carried out in the public interest, for Our legitimate interests, or for the legitimate interests of others. You also have the right to object where Personal Information is Processed for direct marketing purposes or for scientific or historical research purposes or statistical purposes.
Right to Withdraw Consent. In those cases where Processing Your Personal Information or Sensitive Personal Information is based on or otherwise requires consent, and subject to applicable local law which provides otherwise, You have the right to withdraw Your consent at any time. This will not affect the validity of the Processing prior to the withdrawal of consent.
Right to Complain. If You believe We have not Processed Your Personal Information in accordance with applicable law, You may file a complaint with Us using the mechanisms provided for in the “Exercising Your Rights” section at the end of this Privacy Policy.
Right to Appeal. You have the right to appeal any decision made by a Us regarding Your privacy rights identified in this section. To submit an appeal, You may contact Us using the information contained in the “Contact Information” section below.
Promotional Offers from the Company. You have the right to opt-out of Our use of Your contact information to promote Our own or third parties’ products or services. This opt out does not apply to information provided to Us as a result of a product purchase, warranty registration, product service experience or other transactions.
Right to Non-Discrimination. We will not discriminate against You for exercising any of Your rights identified in this section of the Privacy Policy. For example, charge You a different price, or provide a different level or quality of goods or services just because You exercised Your rights under this section of the Privacy Policy; however, We may offer You financial incentives that can result in different prices, rates, or quality levels, provided that (i) You provide Your revocable, opt-in consent to participate in such financial incentive programs, (ii) the financial incentives reasonably relate to the value of Your Personal Information, and (iii) We provide written terms that describe the program’s material aspects. Furthermore, there may be situations where Your Personal Information is required by Us, either directly or indirectly, in order for Us maintain a relationship with You. Please refer to the “Consequences of Not Providing Your Personal Information” section of this Privacy Policy for more information.
As a reminder, when You are a B2B Representative or an End User and We act as a Processor with respect to Your Personal Information, the B2B Party with whom You have a relationship is responsible for providing appropriate notices and disclosures to You about how they Process Your Personal Information and You must refer to that B2B Party’s privacy policy or other notices for information regarding their privacy practices, Your rights, and how You exercise those rights.