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Privacy Policy

Updated: 18th May, 2018

Privacy Policy sets out how VPG uses and protects any information that you give to us. By using the Sites you agree to the terms of this Privacy Policy. The Privacy Policy explains how VPG may:

  • collect
  • use and
  • disclose

information we obtain through the “Sites.” The term “VPG,” “we,” and “us” includes VPG Inc. and our affiliates and subsidiaries.

The “Sites” means collectively any website, mobile application or Internet service under the control of VPG Inc., whether partial or otherwise, in connection with VPG’s online presence.

Personal Data” means any information that relates to a (directly or indirectly) identified or identifiable individual, such as: name, address, email address or phone number.

This Privacy Policy sets out how VPG uses and protects any information that you give to us. We respect your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, transfer, process, use and disclose your data and sets out our security practices. By providing us with your personal information, you agree and consent to its transfer, processing, use and disclosure as outlined in this Privacy Policy. Information about the operator of websites or mobile applications (and VPG entity controlling any Personally Identifiable Information (PII) that is collected) can be found on the footer and/or contact page of websites and in the licensing agreement of mobile applications.

What we collect

We collect personally identifiable information (PII) that you provide to us, which is information that identifies you as an individual. We only do this when you have agreed to our request for that information. This PII may include your:

  • name
  • address
  • telephone number
  • e-mail address

How we use your PII

By providing your PII, you agree that, where it is permitted by local law or where you have agreed to receiving these communications from us, we may use the information:

  • to improve our level of service
  • to improve the content of our communications
  • to provide you with tips, helpful information, product news and updates
  • to notify you of our new products and services
  • to seek your views on our products and services
  • to consider your application for employment
  • to respond to your requests
  • for other purposes that may be detailed on the website or mobile application
  • for other purposes that may be detailed on the website or mobile application

Website and mobile application usage information

We also automatically collect information about your computer browser type and operating system, websites you visited before and after visiting our websites, standard server log information, Internet Protocol (IP) addresses, GPS location data, mobile phone service provider, and mobile phone operating system. We aggregate this information to understand how our visitors use our websites and mobile applications so that we can improve them and the services we offer.  GPS location data does not typically identify individual users.  We may also share this aggregated information with other companies within the VPG group and with other third parties.  This information includes:

  • the total number of visits to our websites and mobile applications
  • the number of visitors to each page of our websites and mobile applications
  • the domain names of our visitors’ internet service providers.

How we protect your PII

VPG will take appropriate legal, organizational, and technical measures to protect your personal information consistent with applicable privacy and data security laws.  When VPG uses a third-party service provider, that provider will be carefully selected and required to use appropriate measures to protect the confidentiality and security of personal information.  We use a variety of security technologies and procedures to help protect your PII from unauthorised access, use or disclosure.  Unfortunately, the transmission of information via the Internet or a mobile phone network connection is not completely secure.  Although we will do our best to protect your PII, we cannot guarantee the security of the PII you transmit to our websites or mobile applications:  any transmission is at your own risk.  While we cannot guarantee that loss, misuse or alteration to data will not occur, once we have received your information, we will employ appropriate technical security measures to prevent such unfortunate occurrences.

Sharing PII with third parties

We may share your PII with our affiliates, contractors and agents in the normal course of business for delivery of the activities to which you have agreed.  Unless otherwise specified in the website or mobile application, we will not sell or rent PII to other third parties, except that your PII may be transferred to a third party in the event that the business of this site or a part of it and the customer data connected with it is sold, assigned or transferred.  Sometimes we use selected third parties to provide support services in connection with our websites, mobile applications or in the normal course of business.  These parties may, from time to time, have access to your information to enable them to provide those services to us.  We require all companies providing such support services to meet the same standards of data protection as our own.  They are prohibited from using the information for their own purposes.  In particular, we do not allow service providers to use your PII for their own marketing activities.

When we may disclose your PII to others

VPG reserves the right to disclose personal information about you, including your e-mail address, for reporting to government authorities, to parties in relevant legal proceedings as authorized by the presiding court or tribunal and otherwise to the extent required or explicitly authorized by applicable law.  In certain special cases where permitted by local law, we may disclose your PII:

  • when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to you or otherwise injuring or interfering with VPG’s rights, property or operations, other users of this website or mobile application or anyone else who could be harmed by such activities
  • when we believe the law requires it, or in response to any demand by law enforcement authorities in connection with a criminal investigation, or civil or administrative authorities in connection with a pending civil case or administrative investigation
  • in connection with a substantial corporate transaction, such as the sale of a product line or division, a merger, consolidation, asset sale or in the unlikely event of bankruptcy.

PII collected may be transferred to, stored and processed in your country of residence or any other country in which VPG (including its affiliates), subcontractors or agents maintain facilities, including the United States and countries outside the European Economic Area (EEA).  This means that your information may be processed in countries with lower data protection standards than your country of residence. By using our websites and mobile applications, you consent to any transfer, processing or storing of information outside of your country of residence and outside the EEA. We will ensure that if information is transferred outside your country of residence, it will still be treated in accordance with this Privacy Policy.

VPG MAY DISCLOSE YOUR INFORMATION

We may share your information:

  • with our subsidiaries and affiliates, on a need-to-know basis;
  • with our third-party service providers, to provide services on our behalf only when such disclosure is necessary to carry out the requisite services;
  • to comply with legal obligations, including in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements;
  • to protect and defend our rights and property; and
  • with your permission.

We do not rent, sell or share Personal Data about you with other people or non-affiliated companies for their direct marketing purposes, unless we have your permission.

Use of IP addresses

An IP address is a set of numbers that is automatically assigned to your computer whenever you log on to your Internet service provider or through your organisation’s local area network (LAN) or wide area network (WAN).  Web servers automatically identify your computer by the IP address assigned to it during your session online. VPG, or third party companies acting on our behalf, may collect IP addresses for the purposes of systems administration and to audit the use of our websites.  We also may use IP addresses to identify users of our websites when we feel it is necessary to enforce compliance with the websites’ terms of use or to protect our service, websites or other users.

Cookies

Our websites and mobile applications may use technology called “cookies.”  A cookie is a small text file that is placed on your hard disk by a server.  Cookies allow our websites and mobile applications to respond to you as an individual.  The website or mobile application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.  For instance, our server may set a cookie that keeps you from having to enter a password more than once during a visit to a website. You can choose to accept or decline cookies.  Most web browsers automatically accept cookies, but you can usually modify your browser 

setting to decline cookies or receive a warning before a cookie is stored if you prefer.  Please refer to your Internet browser’s instructions or help screen to learn more about these functions and to specify your cookie preferences. If you choose to decline cookies, you may not be able to fully experience the interactive features of our websites or any other websites that you visit.

Below is a list of the types of cookies used on our web sites

Purpose Description Type & Expiry
Performance (i.e., User’s Browser) Our web sites are built using common internet platforms. These have built-in cookies which help compatibility issues (e.g., to identify your browser type) and improve performance (e.g., quicker loading of content). Session
Deleted upon closing the browser
Security (e.g. Asp .NET) Cookies If you register for access to a restricted area, our cookies ensure that your device is logged for the duration of your visit. You will need your username and password to access the restricted areas Session
Deleted upon closing the browser
Site Preferences Our cookies may also remember your site preferences (e.g., language) or seek to enhance your experience (e.g., by personalizing a greeting or content). This will apply to areas where you have registered specifically for access or create an account. Session
Deleted upon closing the browser
 Analytical  We use several third party analytics tools to help us understand how site visitors use our web site. This allows us to improve the quality and content on VPG.com for our visitors. The aggregated statistical data cover items such as total visits or page views, and referrers to our web sites. For further details on our use of Google Analytics, see below Persistent, but will delete automatically after two years if you no longer visit VPG.com
 Site visitor feedback We use a third party survey tool to invite a percentage of visitors to provide their feedback. Cookies are used to prevent visitors from being invited multiple times.
The first cookie (1) is set if the visitor is not invited to participate in the survey, and is used to ensure visitors are not invited after their first page view.
The second cookie (2) is set if the visitor is invited to participate in the survey, and is used to ensure the visitor is not invited again to participate for a period of 90 days.
 Session 
Deleted upon closing the browser Persistent
Deleted automatically after 90 days or presenting survey invite. 
 Social sharing We use third party social media widgets or buttons to provide you with additional functionality to share content from our web pages to social media websites and email. Use of these widgets or buttons may place a cookie on your device to make their service easier to use, ensure your interaction is displayed on our webpages properly (e.g. the social share count cache is updated) and log information about your activities across the Internet and on our web sites. We encourage you to review each provider’s privacy information before using any such service. For further details on our use of social media widgets and applications, see below. Persistent, but will be deleted automatically after two years if you no longer visit VPG.com 

Other third party tools and widgets may be used on our individual web pages to provide additional functionality. Use of these tools or widgets may place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly.

Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors.

BY NAVIGATING ON OUR WEB SITES OR ENTERING YOUR LOGIN DETAILS TO ACCESS AREAS RESERVED FOR REGISTERED USERS, YOU AGREE THAT WE CAN PLACE THESE COOKIES ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.

Google Analytics

VPG uses Google Analytics. More information about how Google Analytics is used by VPG can be found here:http://www.google.com/analytics/learn/privacy.html

To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.

Web beacons

A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. VPG only uses web beacons in accordance with applicable laws.

VPG or its service providers may use web beacons to track the effectiveness of third party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.

You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded.

In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.

Location-based tools

VPG may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

Social media widgets and applications

VPG web sites may include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications may collect and use information regarding your use of VPG web sites (see details on ‘Social Sharing’ cookies above). Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.

In addition, VPG web sites may host blogs, forums, crowd-sourcing and other applications or services (collectively “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any VPG social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.

Information from outside sources

Where permitted by local law, we may also collect legally obtained information from third parties to add to our existing user databases. Some of this information may be PII.  We do this to better target information offerings and promotional campaigns in which we think you would be interested.  Such PII will only be collected and used by us in accordance with the basis on which it was originally provided by the subject, or as otherwise permitted by local law.

Access

We will retain your information only for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.  You may contact us in writing to request the updating, correcting or removal of PII that you have provided to us at any time using the contact information provided at the end of this Privacy Policy. Your local laws may also give you the right to access information that you have provided to us. In some countries, you may need to pay a reasonable fee to meet our costs in providing you with this information.

Links to other websites

Our websites and mobile applications may from time to time provide links to or embed third party websites.  This Privacy Policy does not apply to those websites.  If you choose to enter such a linked site, you agree that we are not responsible for the availability of such websites and do not review or endorse and shall not be liable, directly or indirectly, for:

  • how these websites treat your PII
  • the content of such websites
  • the use that others make of these websites.

Please ensure you check the legal and Privacy Policys posted on each website or mobile application you access before entering any PII.

Use of our websites and mobile applications by children

Unless otherwise explicitly stated, websites and mobile applications on which this Privacy Policy appears are not intended or designed to attract children under the age of 13.  We do not knowingly collect PII from visitors in that age group via these websites or mobile applications.  On those websites or mobile applications that are intended for use by children under the age of 13, we only collect PII with the explicit consent of a parent or guardian.

Changes

We may occasionally update this Privacy Policy.  If the changes we make are material, we also may post a notice regarding the changes on our websites or mobile applications and related licensing agreements.  We encourage you to periodically review this Privacy Policy to stay informed about how we are helping to protect the PII we collect. Your continued use of our websites and mobile applications constitutes your agreement to the Privacy Policy and any updates. Subsequent changes in this Privacy Policy will not apply to data that were collected before the change is made.

This Privacy Policy was last updated on 18 May 2018.

YOUR RIGHTS

You may have the right under applicable law to request access to and receive information about the Personal Data we maintain about you, update and correct inaccuracies in your Personal Data, and have the information blocked or deleted, as appropriate. You may also have the right to object and withdraw your consent to the processing of your Personal Data.

Contact us

References to “VPG,” “we,” “us” and “our” are references to Venus Pharma GmbH and its affiliates. Please address any questions, comments and requests regarding this Privacy Policy to your local VPG affiliate using the contact information below. If you contact us, please note the name of the websites you have visited, as well as how we may contact you.

CONTACT US:

If you have any questions about this privacy policy or if you’d like to exercise your choices or rights, you can email at vc@www.venuspharmagmbh.de, or write to the VPG Head Office at Am Bahnhof 1–3, 59368 Werne, Germany.

We are acting as the controller for the data processing within the meaning of the GDPR.

To understand more about privacy policy, access your personal information, ask questions about our privacy practices or issue a complaint, please contact our data protection officer within the meaning of the GDPR at dpo@venuspharmagmbh.de