Table of Contents
- Information Collection
- Personal Information Usage
- Non-Personal Information Usage
- Protection for Children
- Blogs and Social Networking
- Promotions or Offers
- Information Security
- Retention of Personal Information
- Your Privacy Rights and Choices
- Data Transfers
- Third-Party Content
- Communication with Vistex
- Do Not Track
- Data Storage and Transfer
- E.U.-U.S. and Swiss-U.S. Privacy Shield Program
- Questions, Comments, Concerns
- Effective Date
2. Information Collection – Vistex may collect personal information from you when you use the Site, including without limitation when you register with the Site for promotions, rewards, sweepstakes, mailing lists, online surveys, seminars, training or when you voluntarily submit personal information to Vistex for any other reason. Personal information is any information that may be used to identify an individual, which may include full name, e-mail address, postal address, phone number, job title, and name of company/organization.
3. Personal Information Usage – Vistex will only use personal information as described herein, unless you have specifically consented to another type of use, either at the time the personal information is collected from you or through some other form of consent. Vistex may use your personal information to improve our Website and its offering to you, personalize your interaction with the Website, keep you up to date on our latest announcements, products, services, or training, and bring you special offers that you elect to receive from Vistex. Additionally, your personal information may be used by this website to complete transactions for services rendered or for fulfillment of services, products or training that you may have ordered or received as participants of any special membership or rewards programs that are run from this Site by Vistex. Vistex may also use your personal information to send you direct marketing information or contact you for market research purposes, where applicable. At any point in time, Vistex may also disclose your personal information as required by law or legal process.
As a software and services firm, Vistex may also share your personal information with our subsidiaries or vendors in accordance with this policy and to fulfill the requested services.
- Your personal information will only be shared outside of Vistex where the following circumstances are met:
- 3.1 When we have your consent
- 3.2 When we need to share your information to provide the service or product you have requested
- 3.3 When we need to send the information to companies who work on behalf of Vistex to provide a product or service to you
- 3.4 Vistex will only send the elements of your personal information that are required to complete the transaction and obtain the service/product
- 3.5 When required to do so, we will disclose your personal information to federal, state and local law enforcement officials, to enforce the law, or in urgent circumstances, to protect your personal safety, the safety of others or our websites
- 3.6 In connection with an investigation of suspected fraud or a violation of our terms, conditions, policies or guidelines
- 3.7 If a Vistex employee, as required to fulfill the conditions of employment. If a job applicant, as necessary to evaluate suitability for open positions
- 3.8 In connection with any merger, change of control, or sale involving all or a part of Vistex, Inc.
4. Non-Personal Information Usage – Vistex may automatically collect, from you and your computer, certain non-personal information, which Vistex may use for various purposes, both online and off-line. For example, Vistex may log certain aspects of your visit to this Website, such as your IP address and your session ID, your browser type, origination and destination domain, as well as other types of information related to the online user experience. This non-personal information may be added to aggregate user metrics for the Site and may be used to improve your future experience and our service offerings to you. We may share aggregated anonymous information with third parties, but this aggregated anonymous information cannot be matched with you personally unless you voluntarily share your personal information with the third party advertisers.
5. Protection for Children – Vistex does not knowingly solicit or collect personally identifiable information from children under the age of 13 on the Site. If at any time in the future we plan to collect personally identifiable information from children under 13, such collection and use shall be done in compliance with the Children’s Online Privacy Protection Act and appropriate consent from child’s parent or legal guardian will be sought. When Vistex becomes aware the personally identifiable information from a child under 13 has been collected without such child’s parent or guardian’s consent, Vistex will use all reasonable efforts to promptly delete such information from its database.
7. Blogs and Social Networking – You should be aware that information which is voluntarily included and transmitted online in a publicly assessable forum such as a blog, chat room or social networking service may be viewed and used by others without any restrictions. Vistex is unable to control such uses of your information, and by using such services and publicly posting your information you assume the risk that the information provided may be viewed and used by third parties for any number of purposes.
The Site may enable you to integrate with certain third-party sites and services, such as social networking services, through features including Facebook Connect, Facebook “Like” buttons and otherwise. These features may enable integration and/or access to your social networking accounts. We do not control your social networking profile, modify your social networking privacy settings or establish rules about how your personally identifiable information on the social networking services be used. You are encouraged to read all policies and information on the applicable social networking services to learn more about how they handle your information before using any such features made available to you on the Site. Vistex is not responsible for any acts or omissions by any social networking service provider or their platform.
8. Promotions or Offers – Vistex may provide the opportunity to participate in promotions or offers on our Site. If you participate, Vistex will request certain personal information from you. Participation in these promotion or offers is completely voluntary. The requested information typically includes contact information (such as name, e-mail address, company name and telephone number and/or demographic information). Vistex uses this information to notify participants and send other forms of communication, such as e-mail newsletters. Subject to section 3, Vistex will not share personal information you provide through a promotion or offer with other third parties, unless Vistex gives you a prior notice and choice.
9. Information Security – Access to certain Vistex web pages, services, products and activities may require a username and a password. It is your responsibility to maintain the confidentiality of your username and password information. In certain sections of our website, Vistex may use industry-standard encryption and secure databases to enhance the security of data transmissions. We also have reasonable security measures in place in our physical facilities to protect against the loss, misuse or alteration of information that we have collected from you at our Site.
We maintain physical, technical, and administrative safeguards consistent with legal requirements and designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. While Vistex strives to preserve your personal information on our network, due to the inherent security risks of storing and transferring data on the wired or wireless Internet, no network is fail-safe and Vistex cannot guarantee the security of the information you transmit to us. Vistex recommends that you change your password frequently, where applicable, and that you use a latest version browser.
We will notify you in the event we become aware of a security breach involving your personally identifiable information (as defined by the applicable state and federal laws) stored by or for us. By disclosing your email address to us for any reason, you expressly consent to receive electronic notice from us in the event of such a security breach.
10. Retention of Personal Information – To the extent permitted or required by applicable law, we retain personal information we obtain about you as long as: (a) we need the information for the purpose(s) for which we obtained it, in accordance with this Policy; or (b) we have another lawful basis, as stated in this Policy or at the point of collection, for retaining the information beyond the period for which it is necessary to serve the initial purpose for collecting the personal information.
11. Your Privacy Rights and Choices – Certain data protection laws may provide you with more privacy rights than those listed above, depending on your citizenship or residency.
A. Privacy Rights for Individuals in the European Economic Area (“E.E.A.”)
Under the European Union’s General Data Protection Regulation (“GDPR”), individuals in the E.E.A. have additional privacy rights:
- Right to be Informed. Individuals have the right to transparency regarding our collection of personal information.
- Right of Access. Individuals have the right to know exactly what information is held about them and how it is processed.
- Right of Rectification. Individuals will be entitled to have personal data rectified if it is inaccurate or incomplete.
- Right to Erasure. Also known as ‘the right to be forgotten’, this refers to an individual’s right to having their personal data deleted or removed without the need for a specific reason as to why they wish to discontinue.
- Right to Restrict Processing. An individual’s right to block or suppress processing of their personal data.
- Right to Data Portability. This allows individuals to retain and reuse their personal data for their own purpose.
- Right to Object. In certain circumstances, individuals are entitled to object to their personal data being used.
- Rights of Automated Decision Making and Profiling. The GDPR has put in place safeguards to protect individuals against the risk that a potentially damaging decision is made without human intervention.
If you wish to exercise your rights under the GDPR, please contact us using any of the methods provided in the “Contact Us” section below. You can also contact the appropriate National Data Protection Authority by visiting the following website: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
B. Your California Privacy Rights
If you are a California resident, you may also have additional privacy rights under the California Shine the Light law (Civil Code Section § 1798.83) and the California Consumer Privacy Act (“CCPA”) (Civil Code Section § 1798.100).
The Shine the Light law permits users of our Website and our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com or write us at Attn: Vistex Privacy Office, 2300 Barrington Road, 7th Floor, Hoffman Estates, IL 60169.
12. Data Transfers – Your information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. We may transfer personal information to the United States or elsewhere and process it there, in accordance with applicable law and regulation and using appropriate safeguards when necessary.
13. Third-Party Content – In some cases, third-party websites are provided. These links are provided solely as a convenience to you. If you use these links, you will leave the Site. Vistex has not reviewed all of these third-party sites in their entirety and does not control nor is responsible for any of these sites, their content or their privacy policies. Thus, Vistex’s provision of such links is not an endorsement and Vistex does not make representation about them or any information software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third-party websites linked to the Site, you do so at your own risk.
14. Communication with Vistex – Except as set forth in any other agreements between you and Vistex that specifically provide otherwise, any communication or material you transmit to us electronically, including any data, questions, comments, suggestions or the like is, and will be treated as, non-confidential and non-proprietary; anything you transmit or post may be used by us for any purpose, including, but not limited to, reproduction, disclosure, transmission, publication, broadcast and posting; and you expressly agree that we are free to use any ideas, concepts, know-how or techniques contained in any communication you send to us without compensation and for any purpose whatsoever including, but not limited to, developing, manufacturing and marketing products and services using such information.
16. Do Not Track – Certain web browsers and other devices you may use to access the Site may permit you to indicate your preference that you do not wish to be “tracked” online. At this time, the Site does not respond to “Do Not Track” signals.
17. Data Storage and Transfer – This Website may or may not be maintained in the United States of America. By using this Website to the extent applicable to users outside of the United States of America, you freely and specifically give us your consent to import/export your personal information to the USA or elsewhere. If we transfer personal information and process it in the USA or elsewhere, it will be done in accordance with applicable law and regulations and using appropriate safeguards when necessary.
18. EU-U.S. and Swiss-U.S. Privacy Shield Program – Vistex operates in a global market, and may have data that originates from non-US sources. To that end, Vistex complies with the EU-U.S. and Swiss-U.S. Privacy Shield Principles as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from EU member countries, the United Kingdom, and Switzerland. As a prerequisite for participation in the Privacy Shield, Vistex must comply with the following Privacy Shield Principles: notice, choice, accountability for onward transfer, data integrity and purpose limitation, access, security, data integrity and enforcement. Please refer to the Vistex EU-U.S. and Swiss-U.S. Privacy Shield Notice for more information.
19. Questions, Comments, Concerns – Vistex respects your privacy and is committed to protecting the personal information you share with us. You may contact Vistex with questions, comments or concerns regarding your individual privacy issues that may arise as a result of using the Site at firstname.lastname@example.org or through postal mail:
- Vistex, Inc.
- Attn: Vistex Privacy Office
- 2300 Barrington Road
- Hoffman Estates, IL 60169
For residents within EU member countries, you may contact Vistex GmbH with questions, comments or concerns regarding your individual privacy issues that may arise as a result of using the Site at email@example.com or through postal mail:
- Vistex GmbH
- Altrottstrasse 31
- D-69190, Walldorf
20. Effective Date – This policy was placed in effect on December 14, 2017.
Last Modified: December 14, 2020.