- When we say ‘we’, ‘us’ or ‘VersDivers’ It’s because that is who we are and we own and run the ‘Sites’.
The type of personal information we collect
- We collect certain personal information about visitors and users of our Sites.
- The most common types of information we collect include things like: user-names, member names, email-addresses, IP addresses, other contact details, survey responses, blogs, photos, payment information, support queries, forum comments (if applicable), content you direct to us (like product reviews etc.), your actions on our Sites (include any selections or inputs into items) and web and email analytics data. We will also collect personal information from job applications (such as, your CV, the application form itself, cover letter and interview notes).
How we collect personal information
- We collect personal/professional information directly when you provide it to us, automatically as you navigate through our Sites, or through other people when you use services associated with our Sites.
- We collect your personal information when you provide it to us when you complete a membership registration and buy or provide items or services on our Sites, subscribe to a newsletter, email list, submit feedback, enter a contest, fill out a survey, or send us a communication.
Personal information we collect about you from others
- Although we generally collect personal information directly from you, on occasion, we also collect certain categories of personal information about you from other sources. In particular:
- Financial and/or transaction details from payment providers in order to process a transaction.
- Third party service providers (like Google, Facebook, Twitter,… ), which may provide information about you when you link, connect, or login to your account with the third party provider and they send us information such as your registration and profile from that service. The information varies and is controlled by that service provider or as authorized by you via your privacy settings at that service provider.
- Other third party sources/partners, whereby we receive additional information about you (to the extent permitted by applicable law), such as demographic data or fraud detection information, and combine it with information we have about you. For example, fraud warnings from service providers like identity verification service. We also receive information about you and your activities on and off the VersDivers Sites and or platforms through partnerships, or about your experiences and interactions from partner and networks. We also receive information about you as a rights holder from our third party authors. For example, information in the form of a model release when your image is used in an item made available on our Sites.
How we use personal information
- We will use your personal information:
- To fulfill a contract, or take steps linked to a contract: in particular, in facilitating and processing transactions that take place on our Sites, like where you purchase an item from our marketplace.
- Where this is necessary for purpose which are in our, or third parties, legitimate interests. These interests include:
- Operating the Sites
- Providing you with services described on our Sites.
- Verifying your identity when you sign in to any of our Sites.
- Responding to support tickets, and helping facilitate the resolution of any disputes.
- Updating you with operational news and information about our Sites and services.
- Carrying out technical analysis to determine how to improve our Sites and services
- Monitoring activity on our Sites, to identify potential fraudulent activity and to ensure compliance with the user terms that apply to our Sites.
- Managing our relationship with you by responding to your comments or queries submitted to us on our Sites or asking for your feedback whether you want to participate in a survey
- Managing our legal and operational affairs (including, managing risks relating to content and fraud matters).
- Training VersDivers’ staff about how we best serve our user community.
- Improving our products and services.
- Providing general administrative and performance functions and activities.
- Processing your job application to VersDivers.
- Were you give us consent:
- Providing you with marketing information about products and services which we feel interest you.
- For the purpose we are required by law.
- For the purpose of responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.
When we disclose your personal information
- We will disclose personal information to the following recipients:
- Intern in VersDivers located in Belgium.
- If applicable, authors of any items or services made available to you, so they can facilitate support and license validation, who are maybe located in any of the countries our products are available in.
- Subcontractors and service providers who assist us in connection with the ways we use personal information (as set out above), in particular: website hosting providers, recruitment agencies, marketing and analytics services, security and fraud prevention services, subscription management services, payment processing services, identification services, operational tooling services. Nothing that our subcontractors and services providers may also transfer and access such information from other countries in which they have operations.
- Our professional advisers (lawyers, accountants, financial advisers etc.).
- Regulators and government authorities in connection with our compliance procedures and obligations.
- A purchaser or prospective purchaser of all or part of our assets our business, and their professional advisers, in connection with the purchase.
- A third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity.
- A third party, in order to enforce or defend our rights, or to address financial or reputational risks.
- A rights holder in relation to an allegation of intellectual property infringement or any other infringement.
- Other recipients where we are authorized or required by law, or requests by government, a court of law, or law of enforcement authorities, to do so.
Where we transfer and/or store your personal information.
- We are based in Belgium so your data will be processed in Belgium. Some of the recipients we have described in section 10 above, and whom we disclose your personal/professional information, are based in places like Belgium, Austria, Canada, Ireland, Mexico, Philippines, Poland, UK, Germany, Netherlands, France and the US.
We do this on the basis of your consent to this policy. In order to protect your information, we take care where possible to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.
How we keep your personal information secure
- We store personal information on secure servers that are managed by us and our service providers, and occasionally hard copy files that are kept in a secure location in Belgium. Personal information that we store or transmit is protected by security and access controls, including username and password authentication and data encryption where appropriate.
How you can access your personal information
- You can access some of the personal information that we collect about you by logging in to your account. You also have the right to make a request to access other personal information we hold about you and to request corrections of any errors in that data. You can also close the account you have with us for any of our Sites at any time. To make an access or correction request, contact our support using the contact details at the end of this policy.
Marketing choices regarding your personal information
- Where we have your consent to do so (if you have subscribed to one of our email lists or have indicated that you are interested in receiving offers or information from us), we send you marketing communications by email about products and services that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the ‘unsubscribe’ facility provided in the user panel itself.
- You also have choices about cookies as described below. By modifying your browser preferences, you have the choice to accept all cookies, If you choose not to accept all cookies our Sites will not work properly.
Cookies and web analytics
- When you visit our Sites, there’s certain information that is recorded which is generally anonymous information and does not reveal your identity. If you’re logged into your account some of this information could be associated with your account. We’re talking about the following kind of details:
- Your IP address or proxy server’s IP address
- The domain name you requested
- The name of your internet service provider is sometimes captured depending on the configuration of your ISP connection.
- The date and time of your visit to the website.
- The length of your session
- The pages which you have accessed.
- The number of times you access our Sites within any month.
- The file URL you look at and information relating to it.
- The website which referred you to our Sites.
- The operating system your computer uses.
- The technical capabilities of your web browser.
Information about children
- Our Sites are not suitable for children under the age of 16 years, so if you are under 16 we ask that you do no use our Sites or give us your personal information. If you are from 16 to 18 years, you can browse the Sites but you’ll need the supervision of a parent or guardian to become a registered user. It’s the responsibility of the parents or guardians to monitor their children’s use of our Sites.
Information you make public or give to others
How long we keep your personal information
When we need to update this policy
- When we do a change of the policy, we’ll make sure to notify you about such changes, when required. A copy of the latest version of this policy will always be available on this page.
- If you have any questions about our privacy practices or the way in which we have been managing your personal information, please contact our privacy department. Information is in the bottom of this page.
How can you access your personal information
- We are a GDPR (General Data Protection Regulation 2016/679) compliant business and therefor you are entitled to ask us to port your personal information, to erase, or to restrict its processing. You also have rights to object to some processing that is based on our legitimate interests, such as profiling that we perform for the purpose of direct marketing, and where we have asked for your consent to process your data, to withdraw this consent as more fully described below.
- These rights are limited in some situations, for example, we can demonstrate that we have legal requirements to process your personal information. In some instances, this means that we may retain some data even if you withdraw your consent.
- Where we require your personal information to comply with legal or contractual obligations, then provision of such data is mandatory. If such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In all other cases, provision of requested personal information is optional.
- If you have unresolved concerns you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.