Privacy Policy

The Company, Vero Learning LLC (hereinafter “the Company”) has created its Privacy Policy to inform users of the website related service including the Company’s online prototype, its content, social network, advertising, and promotional communications (collectively, the “Site”) in connection with use of the website. We will take reasonable steps to protect user privacy consistent with the guidelines set forth in our Privacy Policy.

1. WHAT INFORMATION DO WE COLLECT & HOW IS IT USED?

Information You Voluntarily Submit to the Website: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, register for access to the Website, or purchase products or services from the Website. Personal Data may include, but is not limited to, the below:

● Your name and email address

● Your age

● Your address

● Your prior work history, internships/work study

● Your career and social interests

Our legal basis for processing this information is your consent, and by voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to us, you acknowledge and agree that such Personal Data may be transferred and stored from your current location to the offices and servers of Company and the authorized third parties referenced below.

Information We Collect from Others: We may receive information about you from other sources. For example, if you use third-party software through the site, they may transfer information to us for fulfillment. For more information about our use of third-party providers, please see below.

Automatically-Collected Information:We automatically collect certain information about you and the device with which you access Company. For example, when you use Company, we will log your IP address, operating system type, browser type, referring website, pages you viewed, and the dates/times when you accessed the website. We may also collect information about actions you take when using Company, such as links clicked.

2. HOW WE USE YOUR PERSONAL INFORMATION

Vero Learning and its subsidiaries and affiliates may use your personal information in the following ways:

• To operate and maintain the website;
• To create your account, identify you as a user of the website, and customize the website to your account;
• To send you promotional information, such as newsletters. Each email newsletter will provide information on how to opt out of future mailings by unsubscribing;
• To conduct a preliminary analysis on participant
• To send you administrative communications, such as administrative emails, confirmation emails, technical notices, updates on policies, or security alerts;
• To respond to your comments or inquiries;
• To provide you with user support;
• To track and measure website performance;
• To process payment for purchases you make through Company
• To protect, investigate, and deter unauthorized or illegal activity;
• To review the effectiveness of our marketing programs and analyze other general demographic trends;
• To notify you of new information or services that may be of interest to you; or,
• To send promotional materials.
• To provide to Hiring Managers and Human Resources personnel

3. LEGAL BASIS FOR PROCESSING PERSONAL DATA

Below are the types of lawful basis that we will rely on to process your Personal Data:

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at info@verolearning.com
• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal or regulatory obligation means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject.
• Consent means where you have consented to a certain use of your Personal Data.

If you are a California resident, the CCPA provides you with the right to opt out of the sale of your personal information. The CCPA defines the “sale” of personal information as:

“Selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to another business or a third party for monetary or other valuable consideration.”

Consumer rights under the CCPA

The CCPA empowers residents of California with the following rights:

The right to be informed of personal information collection and CCPA rights

The right to access personal information that has been collected

The right to have collected information forgotten/deleted

The right to non-discrimination when privacy rights are exercised

The right to opt out of the sale of third-party information

Personal information does not include “publicly available” information. Publicly available information is not covered by the CCPA.

For users in Canada, the privacy policy is compliant with the Canadian Anti Spam Legislation (CASL). From time to time, Company through its own marketing initiatives may send users updates concerning information regarding its Site, and other materials. The CASL establishes three primary rules 1. Senders must have consent from the recipient of the message before sending a CEM. 2. Senders must provide proper identification and contact information to the recipient in each CEM; and 3) senders must have a functioning unsubscribe mechanism in their CEMs. In the event that You as the User elect not to receive Company content to your CEM, You may Opt Out by replying “STOP” in the CEM message field.

4. CHANGES TO THE PRIVACY POLICY AND QUERIES

If we make changes to this Privacy Policy in the future, these will be posted on this page so please do check back from time to time. Any questions regarding our Privacy Policy should be directed to our Data Protection Officer. Please see the section ‘How to contact us’ below.

5. USE OF YOUR PERSONAL INFORMATION FOR MARKETING PURPOSES

(i) We may, with your agreement, give your personal information to other companies within the Company’s network for the purposes of providing products and services you have requested from us and so that those group companies can provide you with information relating to services and further info we think may interest you, by letter, email or on your mobile device.

(ii) If you do not wish to receive this promotional material, you may opt out at any time by:

• Sending an e-mail or writing to us telling us you do not wish to receive further promotional material; or
• Using the "unsubscribe" process described in the promotional material.

6. DISCLOSURES OF PERSONAL INFORMATION TO THIRD PARTIES

(i) We will not disclose any personal information you provide to us to any third party organization outside Company , unless:

• We need to do so to provide you with the products or services you select, for example where we use service providers to provide certain services in support of the Site;
• We are obliged or permitted by law to disclose it (for example if required by law or a court order);
• To protect the rights, property, or safety of Company, its customers, employees, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction; or
• The information is only in the form of aggregated statistics about visitors to the Site in order to describe our services to prospective partners, advertisers, sponsors and other reputable third parties and for other lawful purposes and which contain no personally identifiable information.

7. USE OF COOKIES AND SIMILAR TECHNOLOGY

(i) Cookies are text files stored by your browser software that identify your device to the cookie owner's server. We use cookies to remember you when you visit the Site or other services that we provide to you. There are two main types of cookies that we use:

• 'Session' cookies – where they only last for the duration of your browser session and expire when you close it.
• 'Remember Me' cookies (aka “Persistent” cookies) - cookies that remain on your computer after you close your browser and computer to remember you when you return to the Site.

(ii) We use cookies to:

• Obtain statistical information about your general internet usage and build up a profile of how you and others use the Site, and to improve our Site and deliver a better service to you;
• Remember your session so that you can move from one page to another within the Site;
• Store your preferences; and
• Customize elements of the layout and/or content of the pages of the Site for your preference and ease of use.
• We do not use cookies to store your credit or debit card details.

You can remove cookies from your Browser:

Most web browsers are set up to automatically accept cookies but, if you prefer, you may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting, you may be unable to use the full functionality of the Site and your user experience may be adversely affected. You can learn more about cookies by visiting www.allaboutcookies.org which includes additional information on cookies and how to block cookies using different types of browser.

A simple way of removing cookies is to go to the “Tools” option in your web browser and select “Settings”. To delete all cookies on your computer to date select “Clear Browsing History” and to set options for future cookies select “Cookies” and the options you wish to apply to your web browser.

a) Our cookies

The majority of the cookies used on our Sites are used to record user preferences for repeat visitors and registered users. We use the following types of cookies on our Sites (please note that the exact cookies used on each Sites is dependent on the services provided): cookies-2017.png

If you have a concern about a particular cookie, please contact us.

Cookies are also set by third parties on the Site (such as Google Analytics, Google Maps and Google Ads).

We don't have access to these cookies, we only allow them to be served. However, we may use the anonymized statistical information provided to us by Google Analytics arising from these third party cookies, for example, to monitor usage of the Site or improve the targeting of advertisements to users of the Site.

The third parties that generate these cookies and action tags have their own privacy policies describing how they use the information that they collect. More information about cookies placed by specific third parties and how to restrict or block their cookies can be accessed by following the link to their website and to generate an "opt-out" cookie that will stop any further cookies being written to your device.

Useful links to the various Google services for instructions on how to opt out are:

• www.google.com/policies/privacy/

• tools.google.com/dlpage/gaoptout

• www.google.com/ads/preferences/plugin/

Applications (“Apps”)

Apps downloaded to your mobile phone or tablet may rely on location based services, such as your GPS coordinates to inform you about local forecasts. You may turn off this function within your mobile settings.

Analytical data may be collected from Apps. This is anonymous data from the App in your handset to monitor and optimize features on the handset. This does not identify your handset or you.

Cookies are not used within Apps unless your browser is opened as part of the App. In this case, there may be cookies on the phone web browser.

Vero Learning does not collect personal data unless you are required to provide your email, password, user name and address to receive any of our related subscriptions. This data is not given to any third parties and you will only be contacted for service updates.

8. LINKS TO OTHER WEBSITES

This Site may contain links to other websites which are outside our control and are not covered by this Privacy Policy. Please note that, if you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their privacy policy, which may differ from ours.

9. STORAGE OF YOUR DATA

Information that you submit via the Site is sent to and stored on secure servers generally located in the United States and your information is processed in accordance with the data protection laws of the United States.

10. DATA SECURITY

All information you provide to us is stored on our secure servers or in secure filing systems.

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 us via the internet; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.