Privacy Statement

Last Updated: March 13, 2015

Scope

This privacy policy applies to (www.vce.com, support.vce.com, solutionexchange.vce.com, developer.vce.com, japan.vce.com and partner.vce.com) owned and operated by VCE Company, LLC (“VCE”). VCE Company, LLC (“VCE”) and its subsidiaries respect the privacy of our customers, business partners, and other visitors to our websites who may choose to provide personal information. We recognize the need for appropriate protections and management of personal information that you provide to us. This Privacy Statement will assist you to understand what types of information we may collect, how that information may be used, and with whom the information may be shared when you provide us with information on www.vce.com, support.vce.com, solutionexchange.vce.com, developer.vce.com, japan.vce.com, and partner.vce.com. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

Safe Harbor Compliance

VCE Company, LLC complies with the U.S. – E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. VCE Company, LLC has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view VCE Company, LLC’s certification, please visit http://www.export.gov/safeharbor/.

VCE Company, LLC has received TRUSTe's Privacy Seal signifying that this privacy statement and our practices have been reviewed for compliance with the TRUSTe program viewable on the validation page available by clicking the TRUSTe seal. The TRUSTe program does not cover information that may be collected through downloadable software.The TRUSTe program covers only information that is collected through www.vce.com, support.vce.com, solutionexchange.vce.com, developer.vce.com, japan.vce.com and partner.vce.com.

If you have questions or concerns regarding this Policy, you should first contact us at Privacy@vce.com . If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by Internet (click here), or by fax at 415-520-3420 or mail to TRUSTe Safe Harbor Compliance Dept. (click here for mailing address). If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the company. For information about TRUSTe or the operation of TRUSTe's dispute resolution process, click here or request this information from TRUSTe at any of the addresses identified above. The TRUSTe dispute resolution process shall be conducted in English.

What Personal Information does VCE Collect?

Personal information for purposes of this Privacy Statement is information that identifies or can identify a specific individual.

Collection of personal information online

VCE does collect personal information through www.vce.com, support.vce.com and partner.vce.com. VCE collects information about individuals such as their name, address, telephone number or email address, and contact preferences.

VCE also collects personal information of third parties such as name, email, address and telephone. Portal Managers can create new user accounts account by entering the above personal information. To update, change or delete your account, contact your Portal Manager or contact VCE at Privacy@vce.com .

Collection of personal information offline

VCE may collect information about individuals such as their name, address, telephone number or email address, and contact preferences.

How does VCE use Personal Information?

VCE will use personal information to provide customers and business partners and potential customers and business partners with information and services and to help us better understand your needs and interests. Specifically, we use your information to welcome you and to provide ongoing service and support.

In accordance with applicable law, personal information collected may be transferred, stored and processed in the United States or any other country in which VCE, VCE subsidiaries and affiliates, including its parent companies, or service providers maintain facilities, even if the level of data privacy required is less than that required by the European Union or under Safe Harbor. By entering or otherwise providing your personal data to VCE, you consent to worldwide processing of your personal information.

In addition, we may use aggregate demographic information to improve our websites, but that information is not personally identifiable.

With whom does VCE Share Personal Information?

VCE contracts with its parent organizations and with third party service providers and suppliers (including distributors and resellers) to deliver certain products, services and customer solutions and support. These companies are authorized to use your personal information only as necessary to provide these services to VCE. Examples of such services provided on our behalf include the delivery of mailings, hosting websites, processing transactions, planning events, and the provision of support and other services to enable the use of VCE products. VCE uses a recruitment partner to collect and process career applications. VCE may share personal information with its service providers and suppliers to the extent needed to deliver the service, or to respond to requests for information on products or services, or to otherwise support the customers' business needs. In these instances, you will not have the opportunity to opt out of having your information shared with third party providers and suppliers, and they may contact you directly regarding such products or services.

Third party service providers and suppliers receiving personal information are expected to apply the same level of privacy protection as contained in this Privacy Statement. They are required to keep confidential and secure the personal information received from VCE and they may not use it for any purpose other than as originally intended. However, unless otherwise dictated by law or agreement, VCE is not responsible for any improper use by such parties.

We may also disclose personal information and the content of communications in order to: (a) comply with the law or respond to lawful requests, such as to comply with a subpoena or similar legal process; or (b) act in good faith to protect the rights or property of our business, employees, suppliers or customers, investigate fraud, or respond to a government request; or (c) to any other party with your prior consent to do so.

If VCE is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Unless permitted by relevant laws or you have provided consent, VCE will not share, sell, trade or lease your personal information to others, except as provided in this Privacy Statement.

Choice and Access

We will use your name and email address to send newsletters to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can contact us at http://vblock.vce.com/LP=213.

We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

VCE strives to keep your personal information accurate. We have implemented technology, management processes and policies to maintain data integrity. We will provide you with access to your information when reasonable or in accordance with relevant laws. To protect your privacy and security, we will take steps to verify your identity before granting access or making changes to your data. Requests to delete personal information are subject to any applicable legal and ethical reporting or document retention obligations. To access, delete and/or correct information, you can notify us via any of the methods below; VCE will respond to your request to access and/or correct information within 30 days. Contact VCE at Privacy@vce.com, or VCE Company, LLC, Attn: Office of General Counsel – Privacy Department, 350 Campus Drive, Marlborough, Massachusetts, 01752, USA.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Security of Personal Information

VCE is committed to taking reasonable efforts to secure the personal data you choose to provide us. To protect the privacy of any personal information you may have provided, VCE employs industry-standard physical and logical access controls that change in response to the changing regulatory and threat environments including Internet firewalls, intrusion detection, anti-virus protection and network monitoring. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at Privacy@vce.com.

Tracking Technology and Display of Advertising

As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. Vce.com does not link this automatically collected data to other information we collect about you. Partner.vce.com and developer.vce.com may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality.

Technologies such as: cookies, beacons, tags and scripts are used by VCE Company, LLC. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We use cookies to remember users’ settings (e.g. language preference) and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

Third parties with whom we partner to provide certain features on our site use LSOs such as Flash to collect and store information. To manage Flash LSOs please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

We partner with a third party to either display advertising on our Web site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here) Please note this does not opt you out of being served ads. You will continue to receive generic ads.

Testimonials

We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at referencecentral@vce.com.

Blog / Forum

Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at webteam@vce.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Social Media (Features) and Widgets

Our Web site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Framing

Some of our pages utilize framing techniques to serve content from our partners while preserving the look and feel of our site. Please be aware that you are providing your personal information to these third parties for their use as a service provider and they are required to keep confidential and secure the personal information received and may not use it for any purpose other than as originally intended.

Links to Non-VCE Websites and Third Parties

VCE websites may provide links to third-party websites for your convenience and information. If you access those links, you will leave the VCE website. VCE does not control those sites or their privacy practices which may differ from VCE's. We do not endorse or make any representations about third party websites. The personal data you choose to give to unrelated third parties is governed by their privacy policies and not covered by the VCE Privacy Statement. We encourage you to review the privacy policy of any company before submitting your personal information.

Enforcement of this Privacy Statement

If you have questions regarding our compliance with this Privacy Statement, you should first contact us by making a written submission to VCE's Office of the General Counsel, at 350 Campus Drive, Marlborough, Massachusetts 01752 USA and to Privacy@vce.com .

Changes to this Statement

VCE will review and update this Privacy Statement periodically, and will note the date of its most recent revision above. If we make material changes to this Privacy Statement, we will notify you either by prominently posting a notice of such changes prior to implementing the changes or by directly sending you a notification (sent to the e-mail address specified in your account). We encourage you to review this Privacy Statement frequently to be informed of how VCE is protecting your information.

CONTACT US


Email: Privacy@vce.com
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