Lasted updated: May 21, 2018

Vertellus Holdings LLC and its subsidiaries and affiliates[1] (“Vertellus,” “we”, “us” and “our”) are concerned about protecting your privacy and we want users of our Website (“users, “you,” or “your”) to be familiar with the how we collect, use and disclose information.  This Privacy Statement is part of our Website Terms of Use.  By accessing or using our Site, you agree to be bound by all of its terms and conditions.  If you do not agree to these terms, please do not access or use this Site.

We reserve the right to change this Privacy Statement at any time.  Such changes, modifications, additions, or deletions shall be effective immediately upon notice thereof, which may be given by means including but not limited to posting the revised Privacy Statement on this page.  Your continued use of the Site after such modifications will constitute your agreement to abide and be bound by the modified Privacy Statement.

Information we collect

Personally Identifiable Information

Personally Identifiable Information refers to information that, either alone or in combination with other identifiers, lets us know specifics about you or who you are and may also be called “personal data” in this Privacy Statement.  When you engage in certain activities on this Site, such as sending us a message, we may ask you to provide certain information about yourself, such as your first and last name, e-mail address, employer, and telephone number, and other Personally Identifiable  Information.  Personally Identifiable Information also includes online identifiers, including Your Internet Protocol (“IP”) address.  We may combine Personally Identifiable Information that we collect about you when you use this Site with personal data you provide to Vertellus through other sources, such as product registrations, inquiries, or marketing events.  We will use the combined Personally Identifiable Information in accordance with this Privacy Statement for as long as it is combined.

                Non-Personally Identifiable Information

Non-Personally Identifiable Information refers to any information that does not reveal your specific identity, such as browser information, information collected through cookies, pixel tags and other technologies, demographic information and other information provided by you, and aggregated information.

Collection and Use of Information

Except as otherwise described in this Privacy Statement, we do not use our Website to collect any Personally Identifiable Information about you unless you voluntarily provide it to us, including when you send messages, submit forms or transmit other information by telephone or letter.  We use your IP address to diagnose problems with our servers or software, to administer our Site, and to gather demographic information. 

The provision of Personally Identifiable Information as described in this Policy is partly a requirement to provide you with our services, including use of this Website.

Vertellus relies on the following legal grounds for the collection, processing, and use of Personally Identifiable Information:

•     Consent, as permitted by applicable law;

•     Compliance with legal obligations;

•     Performance of a contract with you;

•     Legitimate interest of Vertellus where the legitimate interest may be:

o     customer relationship management and other forms of marketing;

o     physical security, IT, network security and other operations;

o     prevention of fraud, misuse of company IT systems, or money laundering;

o     intended mergers and acquisitions;

o     to enforce Vertellus terms and conditions;

o     to protect Vertellus rights, privacy, safety or property, you or others; and

o     to allow Vertellus to pursue available remedies or limit the damages we sustain.

 

We will primarily use your Personally Identifiable Information to provide our services or products to you. We may also use Personally Identifiable Information collected through our Site:

•     to respond to inquiries and fulfill your requests, such as to send you email responses or alerts;

•     to improve the content, functionality and usability of our Site;

•     to improve our marketing and promotional efforts;

•     to statistically analyze site use;

•     to improve our product and service offerings;

•     to customize our Site's content, layout, and services;

•     to deliver information or otherwise respond to you;

•     to contact you regarding administrative notices and send you important information regarding the Site, changes to terms or conditions and policies;

•     to resolve disputes, troubleshoot problems, and enforce our agreements with you, including our Site Terms of Use and this Privacy Statement; and

•     for any other purpose identified in an applicable future privacy statement or notice, click-through agreement or other agreement between you and us.

In addition, we may also collect, or our server may collect, Non-Personally Identifiable Information in a variety of ways, including through your browser, when using cookies and other technologies to, among other things, better serve you with more tailored information and to facilitate access to the Site, for information you voluntarily provide, and by aggregating information.

 

 

Sharing of Information

We do not sell, trade, or rent your Personally Identifiable Information to others. However, your Personally Identifiable information may be disclosed:

•     among the subsidiaries and affiliates of Vertellus, for the purposes described in this Privacy Statement, which are jointly responsible for the management of jointly-used Personally Identifiable Information;

•     to Vertellus’ third party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, product distribution, infrastructure provision, IT services, customer service, email delivery services, credit card processing, auditing services, and other similar services to enable them to provide services;

•     to third parties such as agents and distributors to facilitate the sale and distribution of Vertellus products and services, which may include marketing communications;

•     to identify you to anyone to whom you send messages through the Site;

•     to a third party in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Vertellus’ business, assets or ownership interest (including in connection with any bankruptcy or similar proceedings);

•     as we believe to be necessary or appropriate:

◦      under applicable law, including laws outside your country of residence;

◦      to comply with legal process;

◦      to respond to requests from public and government authorities, including those outside your country of residence;

◦      to enforce Vertellus terms and conditions;

◦      to protect Vertellus operations; and

◦      to allow Vertellus to pursue available remedies or limit damages;

•     by you, when you participate in a feature on a Vertellus site that provides the opportunity to interact with Vertellus.  When you use these features you should be aware that any information you submit, including your name, location and e-mail address, may be publicly available to others.  We strongly discourage you from disclosing any sensitive Personally Identifiable Information through these features and we are not responsible for any information you choose to submit therein.

We may also provide Non-Personally Identifiable Information about our customers and related Site information to third-party consultants, but these statistics are provided on an aggregate basis and do not include any Personally Identifiable Information.

User Choice on Collection and Use of Information

If you indicate to us that you are interested in receiving information from us, we may occasionally send you direct mail about products and services that we believe may be of interest to you.  Only Vertellus (or those working on behalf of Vertellus) will send you these direct mailings.  We may provide you with an “opt in” or “opt out” mechanism depending on where you are located when we collect your Personally Identifiable Information.  An “opt in” mechanism will provide you the opportunity to positively indicate that you would like or do not object to our sending you such further communications, and we will not send you further communications unless you “opt in.”  In addition, if you do not want us to use your Personally Identifiable Information for a particular purpose or disclose it to a third party, you may “opt out” at any time by contacting us a provided below.  You also have choice with respect to cookies, as described below.  By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies.  If you choose to reject all cookies some parts of our Site may not work properly for you.

Do Not Track Mechanisms

Your browser may deliver a “Do-Not-Track (‘DNT’) signal,” or similar mechanism for exercising choices about the collection of information about your online activities.  Because of the changing state of technology, we do not guarantee that we will honor DNT signals or similar mechanisms at this time.

Retention of Information

We retain information collected through our Site for as long as the information is necessary for the purposes for which it was collected, or as otherwise permitted by applicable law.  For example, we may retain information (including Personally Identifiable Information) if such retention is reasonably necessary to prevent fraud and abuse, to comply with any legal obligations or satisfy any regulatory requirements, to resolve any disputes or litigation, or as otherwise needed to enforce this Privacy Policy.

To determine the appropriate retention period for the information we collect from you, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we process the data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Security of Information

We rely on current industry standards to secure your Personally Identifiable Information. 

Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be completely secure. As a result, while we strive to protect your Personally Identifiable Information, you acknowledge that: (a) we cannot control security and privacy on the Internet; (b) the security, integrity, and privacy of information or data exchanged between you and us through this Site cannot be guaranteed; and (c) any such information and data may be viewed or compromised when in transit by a third party.

Cookies

When you use our Site we may store cookies on your device in order to facilitate and customize your use of our Site, as well as to provide us with information about your visit to our Site.  A cookie is a small data text file which a Web site stores on your device that can later be retrieved for various purposes as detailed below.  Web browsers typically allow some control of most cookies through browser settings. You are always free to decline our cookies if your browser permits this.  Declining cookies may prevent you from taking full advantage of our Site.

By using our Web Site, you agree that we can place these types of cookies on your device, unless you limit them using your browser settings.

 

For Users in the European Economic Area

For the purpose of the European Union General Data Protection Regulation (2016/679), the data controller is Vertellus.  You may contact us at: 

Chair

Data Privacy Committee

Vertellus

201 N. Illinois Street, Suite 1800

Indianapolis, IN 46204

Phone # +1 (317) 247-8141

privacy@vertellus.com

Vertellus’ representative in the European Union is Vertellus Specialties UK Ltd.  You may contact it at:

Chair

Data Privacy Committee

Vertellus

Ann’s Wharf 112 Quayside

Newcastle upon Tyne, GB NE1 3DX

Phone # +1 (317) 247-8141

privacy@vertellus.com

 

References to ‘personal data’ mean any information relating to an identified or identifiable individual.

Under European Union data protection laws, you have the rights to:

•     withdraw your consent to the processing of your personal data (this will not affect our right to process your personal data up until such time as you provide us with notice that you no longer consent);

•     access to your personal data;

•     receive or ask that we provide you with  (or transfer to a third party) your personal data in a structured, commonly used and machine readable form;

•     request us not to process your personal data for marketing purposes (including profiling to the extent that it is related to our marketing activities).  We will provide you with appropriate choices to opt-in or opt-out as set out above.  you can also exercise the right at any time by contacting us at Vertellus in the manner provided herein; 

•     request us to rectify any inaccurate personal data that we may hold;

•     request us to erase personal data where: (a) it is no longer necessary for us to hold such personal data; (b) you no longer consent to the processing of your personal data; (c) your personal data has been unlawfully processed; or (d) we are otherwise required by law to erase your personal data;

•     make a complaint with the national data protection authority in the country where you are based.

You may contact us at any time at the address and/or email address noted above to exercise any of these rights.

The data that we collect from you will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”).  It will also be processed by personnel operating outside the EEA who work for us.  Where we transfer personal data to a destination outside the EEA, we do so subject to appropriate safeguards.

Children’s Privacy

This Site is not intended for or directed at children under the age of 18 and you must be at least 18 years old to have our permission to use this Site.  Our policy is that we do not knowingly collect, use, or disclose Personally Identifiable Information about visitors that are under 18 years of age.  If you are a parent or guardian of a minor under the age of 18 and believe that we have collected, used, or disclosed such information, please contact us using the contact information contained herein.

International Data Transfers

Information that we collect from you may be stored and processed in and transferred between any of the countries in which we operate.  For European and Asian customers and users, Your Personally Identifiable Information may be transferred outside the European Union and Asian countries for us to provide the services and information you request from us.  Wherever we transfer, process, or store Your Personally Identifiable Information, we will take reasonable steps to protect it.  We will use the information we collect from you in accordance with this Policy and any relevant rules and international standards.  By using this Site, you agree to the transfers of your Personally Identifiable Information described within this section.

Contact Us

If you have any questions about this Privacy Statement, please contact us at: 

Chair

Data Privacy Committee

Vertellus

201 N. Illinois Street, Suite 1800

Indianapolis, IN 46204

Phone # +1 (317) 247-8141

privacy@vertellus.com

 

[1] Nothing in this Privacy Statement is intended to override or minimize the corporate distinctiveness of the various Vertellus entities.  References to corporate relationships do not necessarily represent a reporting structure.