Privacy Statement

Last Updated: July 23, 2014

TRUSTe European Safe Harbor certification

Scope

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 and partner.vce.com.

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 been awarded TRUSTe's Privacy Seal signifying that this privacy statement and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability and choice regarding the collection and use of your personal information. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding VCE’s privacy statement or practices, please contact us at Privacy@vce.com. If you are not satisfied with our response you can contact TRUSTe here. The TRUSTe program covers only information that is collected through www.vce.com, support.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. 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 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.

If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter 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 or you can contact us at Privacy@vce.com

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. When you enter your log in credentials on our log in pages, we encrypt the transmission of that information using secure socket layer (SSL) technology. 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 websites, VCE uses a third party tracking service to collect and/or log Internet Protocol addresses, Internet domain names, the web browser and operating system used to access the VCE website, the files visited, the time spent in each file and the time and date of each visit. VCE collects these through the use of log files and web beacons. Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, web beacons are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by web beacons to our customers’ personal information.

We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole.

VCE also uses cookies on some of its websites. Cookies are identifiers that can be sent from a website via your browser to be placed on your computer's hard drive. Thereafter, when you visit a website, a message is sent back to the web server by the browser accessing the website. You may elect not to accept cookies by changing the designated settings on your web browser. However, not utilizing cookies may prevent you from using certain functions and features of websites. The information collected from the use of cookies is used and analyzed to improve the website, such as by gaining a better understanding of your interests and requirements regarding our website. You can set your browser to notify you when you are sent a cookie, giving you the chance to decide whether or not to accept it. The information we collect and analyze is used to improve our service to you and to personalize your web-browsing experience.

For the VCE website we use the services of a third party vendor to help us measure the effectiveness of our advertising and how visitors use the site. To do this, we use Web beacons and cookies provided by this vendor on our site. The type of information we collect includes the pages visited, navigation patterns, etc. This information helps us learn things such as what product information is of most interest to our customers and what kinds of offers our customers like to see. These third party tracking devices only collect data in the aggregate. Although the vendor logs the information coming from our site on our behalf, VCE controls how that data may and may not be used.

The use of cookies and web beacons by our advertising partners is not covered by our privacy statement. We do not have access or control over these cookies and web beacons.

Websites of VCE subsidiaries or divisions may use similar tracking tools for similar internal business purposes only. These websites may not offer this opt-out functionality.

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 statement 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 not covered by the VCE Privacy Statement. We encourage you to review the privacy statement 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.

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