If you are a past or present employee of Versation who is based in the European Union or European Economic Area, please see the section below on “Information Received from the European Union or European Economic Area.”
What Information Do We Collect?
a) Personal Information
We collect various types of “personal information” depending upon how you use our websites. For example, when you submit an inquiry or respond to a job posting, we need your name and email address to respond.
You will always know when we are collecting personal information because we only collect personal information when you voluntarily submit it to us. If you do choose to give us personal information through our websites, we will collect and retain that information, and you consent to the transfer and storage of that information on our servers. If you choose not to give us personal information, we may not be able to provide you with any services you may request or require.
b) Non-Personal Information
When you use our websites, we may also collect "non-personal information," which is information that, by itself, cannot be used to identify or contact you, such as demographic information (such as your age, gender, income, education, profession, postal code, etc.) or technical information (such as your IP address, the type of browser you are using). Non-personal information may also include information that you provide us through your use of our websites, such as the terms you enter into the search functions of our websites.
c) Cookies and Similar Technologies
The common types of tracking technologies (collectively “cookies and similar technologies”) used by Versation include:
Cookies: A small piece of information sent by a website that is saved in the memory of your computer's browser or device. It holds information a site may need to interact with you and personalize your experience. There are two kinds of cookies: session cookies and persistent cookies. We typically only use session cookies on Versation websites.
Session cookies exist only for as long as you stay on a website or your browser remains open. Once you exit your browser or leave the website, they go away. We use session cookies in some instances to maintain information we need to have in order for you to use our websites, for example, when submitting an inquiry or job application form.
Cookies can be used by a website to recognize you. But that does not necessarily mean any personal information is stored in the cookies. At Versation, we store no personal information about you in the cookies. Anything you choose to tell us about yourself (such as your address and email address) is stored on our secured servers. Please visit www.allaboutcookies.org for more information about cookies and how to disable them.
Web beacons: Small graphic images (also known as "pixel tags" or "clear GIFs") that may be included on our websites, services, applications, or tools, that typically work in conjunction with cookies to identify our users and user behavior.
Similar technologies: Technologies that store information in your browser or device utilizing local shared objects or local storage, such as flash cookies, HTML 5 cookies, and other web application software methods. These technologies can operate across all of your browsers, and in some instances may not be fully managed by your browser and may require management directly through your installed applications or device. We do not use these technologies for storing information to target advertising to you on or off our websites.
We may work with third-party companies, commonly known as service providers, who are authorized to place cookies and similar technologies on our websites with our permission. These service providers help us to provide you with a better, faster, and safer experience.
Do Not Track
Third parties that have content embedded on Versation’s websites (such as buttons, widgets, and other embedded features or content) may set cookies on a user’s browser and/or obtain information about the fact that you visited our websites from a certain IP address. We do not authorize third parties to collect any other personal information from Versation’s websites unless you provide it to them directly.
How Do We Use Your Information?
a) Personal Information
If you choose to provide personal information to us, we may use your information in a number of ways, including the following:
· To respond to inquiries.
· To process responses to job postings.
· To improve our websites and customer service.
· For data processing or storage purposes.
· For marketing and promotional purposes. For example, we send out emails to our customers about products or events that we think may be of interest to them. We also may send you offers for discounts or free services.
· We may send you an email offer. We do this only if you have indicated previously that you are willing to receive email offers. Each time we send an email offer, we provide you with the opportunity to opt out of receiving future email offers.
Versation respects your privacy. We will not call you unless you have selected telephone as your preferred contact method. In addition, your phone number will not be sold or given to any non-affiliated third party.
b) Non-Personal Information
We use the non-personal information we collect to analyze how our websites are being used, and to improve the content on our websites.
How Do We Share Your Information?
a) Affiliated Parties
Except as specifically set forth in this Policy, we do not share your personal information with any non-affiliated third party without your permission. We may disclose aggregate information, such as demographic information, and our statistical analyses to third parties, including advertisers or other business partners. This aggregate information does not include your personal information. We may, however, share your personal information with certain entities that control us, are controlled by us, or are under common control with us (our "Affiliates"), and websites operated by our Affiliates, so that they and we can offer you products and services that may be of interest to you. We require that our Affiliates agree to process such information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures.
b) Service Providers and Third Parties
Versation may share your personal information with outside companies that perform services for Versation. For example, we may retain an outside company to manage a database containing certain customer information or to create and distribute an email offering. When we work with an outside party, we require that these parties agree to process your personal information based on our instructions and in compliance with this Policy. We will take appropriate steps designed to ensure your information will be used solely to provide the services requested by us, and not for other purposes.
c) Other Disclosures
Is My Information Secure?
Versation is committed to doing its best to maintain the security of information collected on our websites. To try to prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have implemented physical, electronic, and managerial procedures to safeguard and secure the information we collect.
There is always some risk in transmitting information electronically. As we deem appropriate, we use security measures consistent with industry standards. However, we cannot guarantee the security of our databases, nor can we guarantee that information you supply won't be intercepted while being transmitted to us over the Internet.
Access and Corrections
You may contact us any time at email@example.com to: 1) see what personal information we have about you, if any, 2) change or correct any personal information we have about you, 3) have us delete any personal information we have about you, 4) express any concern you have about our use of your personal information. It is not technologically possible to change or delete each and every instance of the information we hold on you from our systems, and data may remain in non-erasable or aggregate form. We may retain data for a period in our backup or temporary systems. We may also retain some information for longer periods as required by law, contract, or auditing requirements.
What About Children's Privacy?
It currently is our policy not to knowingly collect personal information from any person under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, he or she should contact us at firstname.lastname@example.org. If we become aware that a child under 13 has provided us with personal information, we will endeavor to delete such information from our files as soon as possible.
Due to the changing nature of the Internet, Versation reserves the right to change this Policy at any time. This Policy was last updated September 6, 2016.
Information Received from the European Union or European Economic Area
For personal information received from the European Union or European Economic Area, Versation, as a subsidiary of Berlitz Languages, Inc. (“Berlitz”), is committed to handling your personal information in accordance with this Policy and the EU-U.S. Privacy Shield Framework as administered by the U.S. Department of Commerce. If there is any conflict between the terms of this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield, and to view Berlitz’ certification, please visit https://www.privacyshield.gov/list.
Versation’s accountability for personal information that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Versation remains responsible and liable under the Privacy Shield Principles if third parties engaged by Versation process the personal information in a manner inconsistent with the Principles, unless Versation proves that it is not responsible for the event giving causing the damage.
If you are a past or present employee of Versation who is based in the European Union or European Economic Area, Versation may collect certain personal information in the context of your employment with Versation or an agent of Versation, such as your contact information, employment and academic history, financial information, age, gender, nationality, date and place of birth, marital status, language skills, employee and government IDs, income, dates of employment, and tax information (“Human Resources Data”). Human Resources Data is transferred and processed for purposes of administration and communication, and to comply with labor law requirements.
As further explained in the "How Can You Contact Us?" section below, we encourage you to contact us should you have a Privacy Shield-related (or general privacy-related) complaint.
Information Received from Switzerland
For personal information received from Switzerland, Versation, as a subsidiary of Berlitz, is committed to handling your personal information in accordance with this Policy and the principles of the U.S.-Swiss Safe Harbor as administered by the U.S. Department of Commerce. To learn more about the Safe Harbor program, and to view Berlitz’ certification, please visit https://safeharbor.export.gov/companyinfo.aspx?id=32762.
How Can You Contact Us?
If you have any questions or comments about this Policy, please use the Contact form or send an email to email@example.com. Complaints will be resolved internally in accordance with Versation complaints procedures. If you live in the European Union, European Economic Area, or Switzerland and efforts to resolve the matter internally are unsatisfactory, the complaint may be submitted to the American Arbitration Association (http://www.adr.org), which has been selected as the independent recourse mechanism to resolve complaints and disputes relating to treatment of data originating in the European Union, European Economic Area, or Switzerland under this Policy. Versation is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
If you are a past or present employee of Versation in the European Union, European Economic Area, or Switzerland, Versation has also chosen to cooperate with and comply with the advice of EU data protection authorities (DPAs) in relation to such unresolved complaints (as further described in the Privacy Shield Principles). Please contact us to be directed to the relevant DPA contacts. As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means.
Residents of the State of California have the right to request a list of all third parties to which we have disclosed certain information during the preceding year for the third parties' direct marketing purposes.
However, it is our policy to neither disclose personal information, nor to sell such information to third parties for direct marketing purposes.
Last Updated: September 6, 2016
Purpose and Use
Our websites are intended solely for persons who are 18 or older. Any access to or use of our websites by anyone under 18 is expressly prohibited. By accessing or using our websites you represent and warrant that you are 18 or older.
Our websites are intended only for use within the United States. Versation makes no representation that the materials on our websites are appropriate or available for use at locations outside of the United States, and access to them from territories where the content is illegal is prohibited. If you access our websites from a location outside of the United States, you are responsible for compliance with all local applicable laws, statutes, ordinances and regulations. By accessing our websites, you consent to having your personal data transferred to and processed in the United States.
Content Ownership and Permissions
Our websites and their content are protected by copyright, trademark, and other laws of the United States and foreign countries. Versation and its licensors exclusively own all right, title and interest in and to the content, including all associated intellectual property rights. You will not remove, alter or obscure any copyright, trademark, service mark or other proprietary rights notices incorporated in or accompanying the content. No licenses or rights are granted to you by implication or otherwise in or to any intellectual property rights owned or controlled by Versation or its licensors.
Versation does not monitor all activity on its websites but reserves the right to do so.
Users are prohibited from violating or attempting to violate the security measures on this site, including, without limitation:
· Attempting to probe, scan or test the vulnerability of the system or network or to breach security or authentication measures without proper authorization;
· Attempting to interfere with service to any user, host or network, including, without limitation, via means of overloading, "flooding", "mail bombing" or "crashing";
· Sending unsolicited email, including promotions and/or advertising of products or services;
· Forging any TCP/IP packet header or any part of the header information in any email; or
· Hijacking all or any part of the website content, deleting or changing any website content, or linking to the websites without our specific written permission.
(b) General Rule
Users agree to use the websites only for lawful purposes.
Versation’s policy is not to accept or consider any unsolicited ideas or materials of any kind. Do NOT submit any such materials. If you violate this prohibition, we reserve the right to consider all materials submitted as non-confidential and free of any claims of proprietary or personal rights. Such material and all rights will be our property, free and clear of any claims by you or others, and we will be able to use them for any purpose, including advertising and promotion, without compensation or any other obligations to anyone, including you.
Internet and Links
Versation assumes no responsibility for the security of our websites or your communications with our websites on the Internet. It is strictly prohibited to link other sites with our websites without Versation’s prior written permission. We may permit some links for convenience, but Versation is not responsible for any unaffiliated sites to which it is linked or for material posted to our websites by anyone other than Versation. Links to unaffiliated sites or resources do not imply any endorsement by Versation of such sites or resources or the content, products, or services available from such sites or resources. You acknowledge sole responsibility for and assume all risk arising from your use of any such sites or resources. Versation makes no representations or warranties about the content, completeness or accuracy of the links or the sites linked to our websites. Please note that the site rules and privacy policies of linked sites may differ from those of Versation and should be reviewed by you when you access any other site.
It is strictly prohibited to disrupt or damage our websites, their contents or their security measures or to harass or disparage Versation or our products or services or personnel. No unsolicited email (spam) may be directed to or through our websites.
Digital Millennium Copyright Act ("DMCA") Notice
Versation Inc. owns, protects and enforces copyright in its own creative materials and respects the intellectual property of others. Our websites contain materials of third parties and links to third-party sites, portals and directories. As a result, materials of third parties, not owned or controlled by Versation, are included in or linked to our websites or are stored or transmitted by or over the Versation websites. To the best of Versation’s knowledge, these materials do not infringe the copyrights of others. Upon receipt of proper notice of claimed infringement (the next paragraph explains how to give proper notice), Versation will respond expeditiously by or disabling access to materials claimed to be infringing or by removing or disabling access to links to such material. It is the policy of Versation to terminate its relationships with third parties who repeatedly infringe the copyrights of others where such parties are known to Versation to be repeat infringers in connection with their use of the Versation websites, links, or storage and communication systems and networks.
How to Provide Notice of Infringement Claims
If you believe that your work has been copied in a way that constitutes copyright infringement, please provide Versation’s Agent for Notice listed below with the following information in a written notice:
(1.) An identification of the copyrighted work (or a list of copyrighted works) that you claim has been infringed upon;
(2.) A description of the material that is claimed to be infringing and provide enough detail that we may find it on our websites;
(3.) Your address, telephone number, and email address;
(4.) A statement that you have a good faith belief that the disputed use is not authorized by you, your agent, or the law;
(5.) A statement that the information in your notice is accurate, and under penalty of perjury, that you are the copyright owner or are authorized to act on the copyright owner's behalf; and,
(6.) Your electronic or physical signature or the electronic or physical signature of the person authorized to act on your behalf.
Versation’s designated Agent for Notice of claims of copyright infringement can be reached as follows:
Service Provider: Versation Inc.
Name of Agent for Notice: Copyright Manager
By mail: 220 Northwest 8th Avenue, Portland, OR 97209
By phone: (503) 827-8021
Versation follows the procedures outlined in the DMCA with regard to appropriate notifications of the user and the complaining party, acceptance of counter notifications, and where indicated, “putback” of the alleged infringing material. Refer to the United States Copyright Office for the provisions of the DMCA at www.loc.gov/copyright/legislation/dmca.pdf.
OUR WEBSITES AND CONTENT ARE PROVIDED “AS IS,” WITHOUT WARRANTY OF ANY KIND, INCLUDING, BUT NOT LIMITED TO, EXPRESS OR IMPLIED, WITH REGARD TO THE INFORMATION, CONTENT, MATERIALS OR PRODUCTS INCLUDED ON OUR WEBSITES. WITHOUT LIMITING THE FOREGOING, VERSATION EXPLICITLY DISCLAIMS ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, QUIET ENJOYMENT OR NON-INFRINGEMENT OF INTELLECTUAL PROPERTY RIGHTS OR OTHER PROPRIETARY RIGHTS, FREEDOM FROM COMPUTER VIRUS, AND ANY WARRANTIES ARISING OUT OF COURSE OF DEALING OR USAGE OF TRADE.
VERSATION MAKES NO WARRANTY THAT THE WEBSITES AND CONTENT WILL MEET YOUR REQUIREMENTS OR BE AVAILABLE ON AN UNINTERRUPTED, SECURE, OR ERROR-FREE BASIS. VERSATION MAKES NO WARRANTY REGARDING THE QUALITY OF ANY CONTENT OBTAINED THROUGH THE WEBSITES OR THE ACCURACY, TIMELINESS, COMPLETENESS OR RELIABILITY OF ANY VERSATION CONTENT OR INFORMATION OBTAINED THROUGH THE WEBSITES.
VERSATION DOES NOT GUARANTEE OR WARRANT THAT THE FILES AVAILABLE FOR DOWNLOADING FROM THE WEBSITES WILL BE FREE OF VIRUSES, WORMS, TROJAN HORSES OR OTHER CODE THAT MAY MANIFEST CONTAMINATING OR DESTRUCTIVE PROPERTIES. VERSATION DOES NOT ASSUME ANY RESPONSIBILITY OR RISK FOR YOUR USE OF OUR WEBSITES.
Limitation of Liability
Some jurisdictions do not allow exclusions of liability for certain types of damages. Accordingly, some of the above limitations may not apply to you to the extent prohibited by law. In such cases, Versation’s liability will be limited to the fullest extent permitted by applicable law.
ANY USE OF THE VERSATION WEBSITES IN VIOLATION OF THESE RULES CONSTITUTES TRESPASS AND/OR INFRINGEMENT OF THE RIGHTS OF VERSATION AND MAY RESULT IN LEGAL ACTION AGAINST YOU.