VERTERA WEBSITE PRIVACY POLICY

INTRODUCTION

This Privacy Policy (the «Policy») defines how VERTERA GEORGIA LLC (Identification number: 405587397; address: Georgia, Tbilisi, Vaja-Pshavela ave. 29a, 0177 (“Company”, “we”, “VERTERA”) collects, uses and shares information about you, if such information was obtained by the Company through the online interfaces used on the site verterage.com (the «Site»). Please read this Policy carefully and accept it by placing ☑ next to the box «I have read and accepted the terms of the Privacy Policy». This Policy is applicable to the usage of the Site by Visitors, Customers and Partners as well.

This Policy only applies to information we process. It does not apply to the practices of other companies. Information on our products’ may contain links to third party websites, and any information you provide to those sites will be covered by privacy policies they may have. Please be sure to read the privacy policies of any third-party sites you visit. It is those sites' responsibility to protect any information you give them, so we can't be held liable for their wrongful use of your personal data.

We may update this Policy from time to time and will notify you of changes to this Policy affecting your rights by email and/or by posting on our Site.

1. TERMS FOR ACCESS TO THE SITE

By providing services through the Site and its services, the Company, acting reasonably and in good faith, presumes that the User:

has all necessary rights permitting him/her to register and use this Site and related services. Please note that we do not collect any personally identifiable information from a person under the age of 18. If you believe that a person under the age 18 has provided us with any personal data, please contact our customer support;
provide accurate information about himself/herself to the extent necessary to use the Site.

2. PURPOSES OF PERSONAL DATA PROCESSING

The Company processes information about Users, including their Personal Data, in order to fulfill the Company's obligations to Users regarding the use of the Site.

For the purposes of the Site use Personal Data shall mean any information related directly or indirectly to a specific or identifiable individual (Personal Data subject), and processing shall mean any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of Personal Data.

3. TYPES OF PERSONAL DATA COLLECTED AND PURPOSE OF USE

3.1. TECHNICAL DATA

The Company automatically collects the following Personal Data when you use the Site:

Technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, login information, browser type and version, time zone settings, browser plug-in types and versions, operating system and platform;
Information about your visit to websites, including the full URL of unified resource pointers (URLs) on, through, and from websites (including the date and time); Products you viewed or searched for; page response time, loading errors, the length of time you visit or use certain pages, page interaction information (such as scrolling, clicking, and hovering), and methods used to navigate from the page.

This information is required to improve the operation of the Site, to fulfill our administrative duties and to protect our business interests.

3.2. CONTACTING DATA

In addition, through the communications channels made available on the Website’s “Contacts” webpage, we collect your contact details, such as your name, e-mail address. We collect this information to provide you with the answers, an appropriate response to your inquiries or comments.

3.3. CUSTOMER DATA

If you are registering as a Customer, we may collect the following Personal Data from you:

Your First name and Last name. It is the contractual requirement. If you don’t provide this data, you won’t be able to register as a Customer;
Password. It is the contractual requirement. Without the password you cannot create your account in our online system as the data must be secured;
E-mail address. It is required for confirmations and communications. Without e-mail you will not receive confirmations. Also we use it to communicate with you;
Phone number. We collect this information to manage your registration as a Customer, create and manage your online account, communicate with you; Also it is required for confirmations and for delivering your orders;
Information on your purchases from VERTERA, and information about your preferences for particular types of products, purchasing habits, purchasing history and spending behavior. We collect this information to improve our Site, products, fulfil our administrative purposes and protect our business interests;
Postal address. It is the contractual requirements, if you do not provide it we will not be able to deliver your order.

We may collect other types of personal data in exceptional circumstances only. If we do need to process additional types of Personal Data about you, we will make sure that you are informed about the processing of your Personal Data and that there is a valid legal basis for doing so (for example, your consent).

3.4. PARTNERS DATA

If you are registering as a Partner, we may collect the following Personal Data from you:

Your First name, Last name and Middle name. If you don’t provide this data, you won’t be able to register as a Partner;
Your date of birth. Registration only accepted for over 18s, because of the statutory requirement;
Your personal code. We will use this data to verify you as an exact Partner and to pay the rewards according to the Marketing plan of the Company;
Copy of the passport / ID card. We will use this data to verify you as an exact Partner and to pay the rewards according to the Marketing plan of the Company, because of statutory requirements;
Postal address. It is the contractual requirements, if you do not provide it we will not be able to deliver your order;
Registration address. It is our statutory requirements. We cannot offer bonuses without your current address;
E-mail address. It is required for confirmations and communications. Without email you will not receive confirmations. Also we use it to communicate with you;
Phone number. It is required for confirmations and for delivering your orders;
Account number (banking/payment system). It is our statutory obligations, required for paying the bonuses to you;
Password. It is the contractual requirement. Without the password you cannot create your account in our online system as the data must be secured;
Information on your purchases from VERTERA, and information about your preferences for particular types of products. We collect this information to improve our Site, products, fulfil our administrative purposes and protect our business interests.

If you object to the use of your Personal Data to fulfil any of the purposes set out above, please contact us. Whilst your decision to provide your Personal Data to VERTERA is generally voluntary, if you do not provide certain information VERTERA may not be able to accomplish some of the purposes outlined in this Privacy Policy. For example, we may not be able to post products to you without knowing your postal address.

4. WHAT IS THE LEGAL BASIS OF THE USE OF THE PERSONAL DATA?

4.1. PERFORMANCE OF A CONTRACT

As required to establish and fulfil a contract with you (Terms and Conditions), for example, if you make a purchase. This will include purposes of taking payments, communicating with you, providing customer services and arranging the delivery or other provision of products or services. Also, to establish a partnership contact we will need to verify your identity, taking payments, communicating with you, providing partnership services, and providing you with the bonuses and rewards.

4.2. LEGITIMATE INTERESTS:

As required by it to pursue its own legitimate interests, in particular:

to communicate with you (including providing you with information to help you improve your business (such as providing you with training materials and sessions);
to invite you to take part in market research or studies, and attend (business update) conferences;
to help you monitor, improve, administer and protect products, content, services and Sites, both online and offline;
to monitor and ensure compliance by you with its policies and rules;
to monitor any Customer or Partner Account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law; and
to measure or understand the effectiveness of advertising it serves to you and others, and to deliver relevant advertising to you (including, performance of customer satisfaction and similar studies).

4.3. COMPLIANCE WITH A LEGAL OBLIGATION

To ensure compliance with applicable laws and the protection of the Company's legitimate business interests and rights, including, but not limited to, use in connection with legal claims, compliance, regulatory, tax, investigative purposes (including disclosure of such information in connection with legal process or litigation).

4.4. YOUR CONSENT

By signing up for the Site, you, based on your free will and awareness, declare your consent to disclose your Personal data to VERTERA for a designated purpose of performance of the reciprocal contractual obligations (acquirement of products, arrangement of delivery, conduction of payments, provision of customer assistance and necessary communication, performance of partnership services and receipt of correlated bonuses and rewards and etc.) provided thereby in full extent.

Subject to the following, the Company will send you direct marketing in relation to the Company's products and services similar to those which you have already purchased, or other products and services provided by the Company. This will only be sent if you have given your consent to the Company during the Customer’s or Partner’s sign-up process. You can manage your preferences or unsubscribe at any time by the links in e-mails we send you.

5. WHO WILL YOUR PERSONAL DATA BE SHARED WITH?

VERTERA has several partners to operate the service. We may need to share some of your personal information with them to provide the service to you. These parties can be categorized as:

Companies providing courier services that deliver goods at the postal addresses indicated by you;
Postal services;
The products' suppliers that deliver goods directly to you;
Other VERTERA group companies, including WR International AG for group level analytics;
Government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of its own legitimate interests in compliance with applicable laws.

This sharing will be for the purposes set out above or to comply with specific legal obligations to which we are subject.

VERTERA uses appropriate safeguards to protect personal information which is transferred to countries outside of the European Economic Area which are considered to provide a lower level of protection for personal information. European Commission-approved Standard Contractual Clauses and other legally acceptable transfer mechanisms are in place with our email system provider and IT support and IT system maintenance suppliers. Contact us using the details set out below to see a copy of the relevant safeguards.

6. DATA STORAGE

When collecting Personal Data of Users and Visitors, the Company provides recording, systematization, accumulation, storage, clarification (updating, modification), extraction of your Personal Data using databases located in the European Union. However, some features and requirements of the service, involve transferring your information to third-party service providers outside the European Economic Area. We have described all those service providers above in the Section “WHO WILL YOUR PERSONAL DATA BE SHARED WITH?”. Where such service providers are not established in a country ensuring an adequate level of protection within the meaning of Regulation (EU) 2016/679, the transfers will be covered by the standard data protection clauses adopted by the European Commission.

The Personal Data that the Company processes would not be stored for longer than it is required for the relevant purposes. The Company will store your Personal Data for the whole period of your contractual relationship with the Company (period of existence of your Personal Account on the Site) and, to the extent permitted, after the termination of this relationship for as long as it takes to fulfill the purposes set out in this Policy.

VERTERA may keep certain information even after deletion of the account, if it is necessary to fulfill the requirements of law, to settle the dispute, to prevent fraud or abuse, and to ensure compliance with provisions of this Privacy Policy. Personal Data of the Visitors having not signed in to the account shall be stored within 12 months in order to analyze behavioral activity. For Customers who have not order products from the Company, we will delete all personal data 12 months after the approval of your account deletion request to analyze Customer’s activity and improve the Site, our products.

For Customers who have ordered any products from VERTERA our data deletion policy is the following:

Order processing information will be kept by VERTERA for 10 years or until tax audit close, whichever is later. Other Personal Data will be deleted in 12 months after the approval of your account deletion.

For Partners:

Order processing information will be kept by VERTERA for 10 years or until tax audit close, whichever is later. VERTERA may use your Personal Data while you are active with VERTERA. In deciding how long to keep personal information after you cease to be active with VERTERA, we take into account any ongoing obligations we may have (e.g. to store the information for accounting purposes) or the length of time given to commence or defend any legal claims.

We will stop processing your data for direct marketing, including profiling activities, if you object to such processing of your data or if you withdraw your consent to processing, where your consent has previously been obtained.

We will stop storage and processing your data if you object to such storage and processing of your data or if you have withdrawn your consent to processing that was previously received by the Company.

7. WHAT COOKIES WILL BE USED ON THE SITE?

The Sites uses cookies (small files placed on website users’ hard drive) to distinguish you from other Customers and Partners, using the Site. This helps us to provide you with a high quality experience when you browse the Site and also allows us to improve the Site. We use cookies to analyze the flow of information; customize the services, content and advertising; measure promotional effectiveness; and promote trust and safety.

We offer certain services that are available only through the use of cookies. Generally, we use the following categories of cookies:

Strictly Necessary Cookies
Performance Cookies
Functionality Cookies
Google Analytics

Some cookies are essential for the operation of the Site. For example, some cookies allow us to identify registered Customers or Partners and ensure they can access the Site. If a registered Customer or a Partner opts to disable these cookies, the Customer, Partner may not be able to access all of the content of the Site.

Other cookies may be used to analyze how Visitors, Customers, Partners use the Site and to monitor Site performance. This allows us to provide a high quality experience by customizing the offering and quickly identifying and fixing any issues that arise. For example, performance cookies may be used to keep track of which pages are most popular and to determine why some pages are receiving error messages.

Functionality cookies are used to allow us to remember Visitors’, Customers’, Partners’ preferences and tailor the Site to provide enhanced features.

We use Google Analytics to understand how Visitors engage with our Site. This means that when you visit our Website your browser automatically sends certain information to Google. This includes, for example, the web address of the page that you're visiting and your IP address. You will find the details of how the Google technology collects and processes data following this link https://www.google.com/policies/privacy/partners/.

If you don’t want the Google Analytics to be used in your browser, you can install the Google Analytics browser add-on. You can find more about the Google Analytics and Google privacy policy https://policies.google.com/privacy.

Visitors, Customers, Partners are always free to decline cookies if their browser permits, although doing so may interfere with their use of the Site. Please find detailed information on how to disable cookies here: http://www.allaboutcookies.org/manage-cookies/.

More detail on how businesses use cookies is available here: http://www.allaboutcookies.org/.

8. RIGHTS OF PERSONAL DATA SUBJECTS

1. The right to be informed

Art. 12-14 GDPR

You have the right to be informed about the collection and use of Your Personal Data, in particular, about purposes for processing of these data, retention periods for that Personal Data, and who it will be shared with. This information must be provided at the time we collect Personal Data from You. If we obtain Personal Data from other sources, we will inform You about this within a reasonable period of obtaining the data and no later than one month, unless You already have the information or if it would involve a disproportionate effort to provide it to You.

2. Right of access

Art. 15 GDPR

You have the right to obtain from the Company confirmation as to whether or not Personal Data concerning You are being processed, and, where that is the case, access to the Personal Data and the following information: the purposes of the processing; the categories of Personal Data concerned; the recipients or categories of recipient to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations; where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from the controller rectification or erasure of Personal Data or restriction of processing of Personal Data concerning the data subject or to object to such processing; the right to lodge a complaint with a supervisory authority; the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

3. Right to rectification

Art. 16 GDPR

You have the right to have inaccurate Personal Data rectified or completed if it is incomplete under request for rectification made verbally or in writing.

4. Right to erasure (‘right to be forgotten’)

Art. 17 GDPR

The GDPR introduces a right for individuals to have Personal Data erased. You can make a request for erasure by contacting our customer support service. Please take a note, the right is not absolute and applies only under certain circumstances, provided in Art. 17 GDPR.

5. Right to restriction of processing

Art. 18 GDPR

You have the right to request the restriction or suppression of your Personal Data. Where processing has been restricted, such Personal Data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State. Please take a note, the right is not absolute and only applies in certain circumstances, provided in Art. 18 GDPR.

6. Right to data portability

Art. 20 GDPR

The right to data portability allows you to obtain and reuse your Personal Data for your own purposes across different services. It allows you to move, copy or transfer Personal Data easily from one IT environment to another in a safe and secure way, without affecting its usability. Please take a note, you have the right to have the Personal data transmitted directly from one controller to another, where technically feasible.

7. Right to object

Art. 21 GDPR

You have the right to object, on grounds relating to your particular situation, at any time to processing of Personal Data concerning you. We will no longer process Your personal data unless we have legitimate grounds for the processing.

You may revoke your consent to the processing of Personal Data at any time. Please be advised that the revocation will only take effect in the future. Any processing that was carried out prior to the revocation shall not be affected thereby.

9. LINKS TO OTHER WEBSITES

The Site may contain links to websites maintained by third parties, whose information and privacy practices are different than ours. We are not responsible or liable for the information or privacy practices employed by such third parties. We encourage you to read the privacy policies of all third-party websites before using such websites or submitting any personal data or any other information on or through such websites.

10. HOW TO CONTACT US

If you have any comments or inquiries about our Privacy Policy, if you would like to update information, we have about you, or to exercise your rights, you may contact us via support@vertera.org