Updated: November 2019
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the EU General Data Protection Regulation (GDPR), the data controller is Verifiable Inc. of 18 Bartol Street #1128 San Francisco, CA 94133. You may contact us to find out more about the way we treat and use personal data via email at [email protected].
IF YOU DO NOT PROVIDE PERSONAL DATA
If we need to process the data you provide us with about yourself to fulfill our service and you fail to provide that data when requested, we may not be able to perform the service, in which case, we may have to cancel a product or service you have with us. We will of course notify you if this is the case at the time.
PRIVACY SHIELD COMPLIANCE
Pursuant to the Privacy Shield Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to [email protected]. If requested to remove data, we will respond within a reasonable timeframe.
Verifiable is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission (FTC). We may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the Privacy Shield Principles, Verifiable commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, United Kingdom, and Swiss individuals with Privacy Shield inquiries or complaints should first contact the privacy team at [email protected].
Verifiable has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumersfor more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
WHAT INFORMATION DO WE USE?
We will collect and process the following data about you:
Information you give us about you. This is information about you that you give us by filling in forms on our website (https://www.verifiable.com/) that you may access directly or through another website, or by corresponding with us by e-mail or otherwise. It only includes basic personal data required for you to be able to use our site, subscribe to our service, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our website. The information you give us may include the following information:
- Full name
- Email address(es)
- Educational information when adding an education credential including School Name, City, State, Degree, Major / Field of Study, and Graduation Date
- License or Certificate information when adding a credential including Certificate Title, Your Name, Issuer, Certificate Number, Issue Date, Expiration Date, Certificate Description, and Course URL
- Additional information that may be contained in a credential that is uploaded to your digital wallet
- Information that may be provided by you through our customer support email, chat, via social media websites or other third-party platforms where we communicate with users. This may include feedback, contact information, identifying information to assist with finding an account, or any other information provided in these interactions.
Information we collect about you. With regard to each of your visits to our website, certain information may be automatically collected and stored about your usage:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information, methods used to browse away from the page, and any email used to contact our customer service;
Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers, search information providers, credit reference agencies).
Posting and Uploading. We collect personal data from you when you provide, post or upload it to our site, such as when you fill out a form, respond to a survey, or add a credential. You don’t have to post or upload personal data; though if you don’t, it may limit your ability to grow and engage with your network over our Services.
HOW DO WE USE THIS INFORMATION?
We will only use personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing to you directly, at any time by contacting us at [email protected].
Information you give to us. We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
- to notify you about important changes to our service.
Information from an organization. Personal Data received from an Organization will be used in accordance with the Organization's instructions and as required by law in order to fulfill credentialing services to the Organization. Verifiable is a processor of the Personal Data provided by the Organization and the Organization is the controller and is solely responsible for the accuracy, integrity, legality, and completeness of the data provided.
The Personal Data provided by an Organization may be used in combination with information provided by you in order to fulfill the Service on behalf of you or the Organization. This includes:
- Issuing a digital credential including using information provided by an Organization to create a verifiable record of your credential.
- Enabling you to claim your digital credential including notifying you about the credential, providing access to it and allowing you to create an account on Verifiable.
- Storing your digital credential in your digital wallet on Verifiable.
- Sharing your digital credentials to social media websites, via email or other third-party platforms with your permission.
- Fulfilling Services to an Organization including managing your issued credentials, providing usage or analytics information, and providing account management.
- Enabling Authorized Users to manage Organization accounts which may include tracking your (if you are an Authorized User) name, email, contact information, or relevant billing information to allow you to administer to your account.
- Enforcing our Terms of Service and other policies.
- To investigate and prevent security issues and/or abuse.
- As required by applicable law, legal process or regulation.
- You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here.
Information we collect about you. We will use this information:
- To administer our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- To improve our website to ensure that content is presented in the most effective manner for you and for your device.
- To allow you to participate in interactive features of our service, when you choose to do so.
- As part of our efforts to keep our website safe and secure.
Information we receive from other sources. We may receive personal data about you from selected third parties that we work with or that provide us with a service (such as payment services for example) and public sources (such as Companies House for example).
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your contact details and technical data that we collect about you, such as your IP address and the way you browse our website to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services through us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages to you at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at [email protected].
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
We will get your express opt-in consent before we share your personal data with any external company for marketing purposes.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email us at [email protected].
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
HOW DO WE SHARE YOUR INFORMATION?
You acknowledge and agree that from time to time we have the right to share your personal information with:
- An Organization which has previously shared your information with us in order to provide Services. This information will be shared in accordance with an Organization's instructions and in agreement between Verifiable and the Organization, and in compliance with applicable law. This includes Authorized users or other Organization representatives.
- Selected third parties that have been granted access to your Personal data in order to provide Services to you and to the Organization including (a) approved Subprocessors available here and (b) select business partners, suppliers and sub-contractors for the performance of any contract we enter into with you.
- Legal authorities or in compliance of legal regulations if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions and other agreements; or to protect the rights, property, or safety of Verifiable, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- Third parties in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets; or if Verifiable or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
WHERE DO WE STORE YOUR INFORMATION?
All personal data we process is processed by our staff in the US, Europe, and outside the EEA.
For the purposes of IT hosting and maintenance this information is located on servers outside the European Economic Area, in North Virginia in the US.
Some of our external third parties such as Google are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the agreements which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us at [email protected] if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Once we have received your information, we have a Data Protection regime in place to oversee the effective and secure processing of your personal data and we will use strict procedures and security features to try to prevent unauthorized access.
However and 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 our website at transmission stage; any transmission is at your own risk.
HOW LONG DO WE KEEP YOUR INFORMATION FOR?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
In some circumstances you can ask us to delete your data. See below for further information.
WHAT ARE YOUR RIGHTS?
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
EXERCISING YOUR RIGHTS
If you wish to exercise any of your rights set out above, please email us at [email protected].
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
EUROPEAN DATA PROTECTION RIGHTS
If you reside in the United Kingdom (UK) or a country within the European Union (EU), or your Personal Data is processed in the UK or a country in the EU, subject to certain exceptions, you have specific rights in regards to your data based on local laws and the General Data Protection Regulation (GDPR) which are described in detail here: https://help.verifiable.com/en/articles/1932359-gdpr-compliance.
You have the right to If you’re based in the EU, you can always file a complaint with the supervisory authority in your Member State. For example, if you’re based in the UK, you can file a complaint with the Information Commissioner’s Office.
CALIFORNIA PRIVACY RIGHTS
Under California Civil Code Section 1798.83, if you are a resident of California and your business relationship with Verifiable is primarily for personal, family or household purposes, you may request certain data regarding Verifiable's disclosure, if any, of Personal Data to third parties for the third parties' direct marketing. To make such a request, please send an email with your request to [email protected] with "Request for California Privacy Information" in the subject line of your email. You may make such a request once per calendar year. If applicable, we will provide you a list of the categories of Personal Information disclosed to third parties for their direct marketing during the immediately preceding calendar year, along with the third parties' names and addresses. Not all Personal Information sharing is covered by Section 1798.83.
We implement security safeguards to protect your data such as HTTPS and regularly monitor our systems for possible vulnerabilities or attacks. Based on the nature of the internet as well as other reasons, we can not guarantee complete security of your Personal Data from being accessed, disclosed, altered or destroyed by breach of our security safeguards. You should take precautions to protect your Personal Data through such means as using a secure password, change your password often, setting up two-factor authentication on your account, using a secure browser, and logging out when using a shared computer.
PROHIBITED USE BY MINORS
Verifiable is a service meant for adult use only and does not promote the Service to children or intentionally collect information from children under the age of 13. If we learn we have collected personal information from an individual under 13, we will delete that information as quickly as possible. If you believe that an individual under 13 may have provided us personal information in violation of this paragraph, please contact us at [email protected] with “Notice of Underage Person” in the subject line.