Privacy Statement

This Privacy Statement is issued by Viaplus, LLC and our affiliates Viaplus India, PTY and Viaplus Europe Limited (“Viaplus”, “we”, “us”, “our”).

The purpose of this notice is to inform you of the data relating to you that we collect and use in connection with the website www.viaplus.com and the uses (including disclosures to third parties) we make of such data. Viaplus is not responsible for the content or privacy practices of any linked sites.

If you have any questions about our use of your personal data, please contact our Data Protection Officer at privacy@viaplus.com.

Personal Data that we collect and process

We collect and process personal data relating to you in connection with your use of this website and our relationship with you. This personal data may include:

Information that you provide in any online contact form including your name, address, phone number and email address.
Any other personal data relating to you that you provide to us or that we generate about you in connection with your use of the website www.viaplus.com.

Website Usage Data

We use a monitoring application to collate and analyse certain statistical information about the use of this website. When you visit our website, the following information is retained about that visit:

IP (Internet Protocol) address;
The number of times per visit a request for data was received from each IP address;
The entry page to and exit page from our website;
The length of time spent on our website;
The IP address of a link if used to access our website;
The identity of any search engine used to access our website;
A list of all the pages visited while in our website; and
The name of the browser used, e.g. Firefox, Chrome, Internet Explorer.

No attempt is made to identify individual users or to associate the technical details listed above with any individual.

Purposes of Processing and Legal Basis

We will use personal data relating to you for the purposes of:

Improving and developing this website;
Processing online queries and contacts;
Generating and analysing statistics regarding usage of this website, including the frequency of use of individual pages (where possible, personal data will be anonymised before being used for this purpose);
Fraud prevention, investigation and detection;
Establishing, exercising or defending legal claims;
Complying with our legal obligations.

The legal bases on which we process your personal data are:

That this is necessary for compliance with a legal obligation that applies to us; or
That you have given your consent to the processing.

Recipients of Data

We may disclose your personal data to other organisations in connection with the above purposes, including:

To third parties who we engage with to provide services to us in connection with this website, such as outsourced service providers, IT services providers and professional advisers;
To other bodies where required or permitted by law, such as law enforcement authorities for the purposes of the prevention, investigation or detection of crime.

Retention

We will not hold your personal data for longer than is necessary. We retain your personal data for as long as we need it for the purposes described in this Notice, or to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise between you and us.

Viaplus does not disclose Personal Information to third parties for direct marketing purposes, nor does it sell Personal Information. Processing of Personal Information will comply with contractual, regulatory, and local legal requirements.

Viaplus stores and destroys Personal Information based on our data retention policies and procedures. We retain data for as long as it serves the purpose of processing for which it was collected or subsequently authorized.

Feedback, queries, complaints and other correspondence submitted on our website or by email are retained for 1 year following conclusion of each case and are then either deleted from our systems or anonymised.

Your rights

Where permitted or required by applicable law, we extend certain data privacy rights to you.

You have the following rights, in certain circumstances and subject to certain restrictions, in relation to your personal data:

The right to request access: You have the right to request Viaplus for copies of your Personal Information that we hold and / or process.
The right to request rectification: We rely on you to ensure the information you provide to Viaplus about you is accurate, complete and current. If any Personal Information is inaccurate or incomplete, you may request that your Personal Information be corrected or completed. You may also request to correct, amend, or delete Personal Information that has been processed in violation of applicable data protection law.
The right to request erasure: You have the right to request Viaplus delete your Personal Information under certain conditions.
The right to withdraw consent: Where you have provided written consent (or positive opt-in) to the collection, processing, or transfer of Personal Information, you may have the legal right to withdraw consent. Where we have processed your Personal Information with written consent (or positive opt-in), you can withdraw that consent at any time. Note – withdrawing consent will not affect the lawfulness of any processing we conducted prior to withdrawal nor will it affect the processing of the Personal Information conducted in reliance on a lawful basis other than consent.
The right to request portability: You have the right to request Viaplus transfer your Personal Information that we have collected to another organization, or directly to you, under certain conditions.
The right to restrict processing: You have the right to request that Viaplus restrict the processing of your Personal Information, under certain conditions.
The right to opt-out of email marketing: You can opt-out of email marketing communications at any time by selecting the email’s “Opt-out” or “Unsubscribe” link, or following the instructions included in each email subscription communication.
California residents have certain other privacy rights as described below:

Disclosure of Personal Information We Collect About You

You have the right to know:

· The categories of Personal Information we have collected about you;

· The categories of sources from which the Personal Information is collected;

· Our business or commercial purpose for collecting Personal Information;

· The categories of third parties with whom we share Personal Information, if any;

· The categories of Personal Information that we disclosed about you for a business purpose; and

· The specific pieces of Personal Information we have collected about you.

· Please note that we are not required to:

o Retain any Personal Information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;

o Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Information; or

o Provide the Personal Information to you more than twice in a 12-month period.

Opt-Out of the Sale of Personal Information to Third Parties

In connection with any personal information we may disclose to a third party for a business purpose, you have the right to know:

· The categories of Personal Information that we disclosed about you for a business purpose.

Please note that under the California Consumer Privacy Act of 2018 (CCPA), we do not sell Personal Information to Third Parties. We do not sell Personal Information of minors under 16 years of age and we will not do so without affirmative authorization.

Cal. Civ. Code § 1798.83 allows you to request opt-out of the disclosure of your personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

· Delete your personal information from our records; and

· Direct any service providers to delete your personal information from their records.

Please note that we may not delete your personal information if it is necessary to:

· Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;

· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

· Debug to identify and repair errors that impair existing intended functionality;

· Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

· Comply with the California Electronic Communications Privacy Act;

· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;

· Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;

· Comply with an existing legal obligation; or

· Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Note that we may be unable to provide you access to your Personal Information in instances where we have destroyed, erased, or anonymized the data, if we are unable to verify your identity using information we have on file for you, or if it would reveal Personal Information about another person. We may also refuse any request if applicable law allows or requires us to do so. We will inform you of the reasons for refusal.

If you choose to contact us to submit a request, you will need to provide us with:

Enough information to identify you (e.g. your full name, address, birthdate, or other identifier); and
A description of what right you want to exercise and the information to which your request relates.

Any Personal Information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or if someone is authorized to act on such person’s behalf.

If you wish to exercise any of the rights set out above, please contact us at privacy@viaplus.com.

Viaplus will not discriminate against individuals for exercising any of their privacy rights allowed or required by applicable data protection law or regulation.

Cookie Policy

This cookie policy relates to www.viaplus.com.

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The text below explains the cookies we use and why.

Cookies used on this site

Strictly Necessary Cookies are cookies that are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Name	Provider	Purpose	Expiry
Cookie Notice	Digital Factory	To advise visitors of cookies and record their accept/reject preferences. To provide a link to online privacy statement.	1 year

Performance Cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

Name	Provider	Purpose	Expiry
Google Analytics	Google	Website audience measuring (number of visitors, most popular pages visited etc.)	1 year

Functional Cookies enable the website to provide enhanced functionality and personalisation. We currently do not use any functional cookies on our website(s).

Targeting Cookies may be set through our site by our advertising partners in order to build a profile of your interests and show you relevant adverts on other sites. We currently do not use any targeting cookies on our website(s).

How do I change my cookie settings?

It is usually possible to stop your browser accepting Cookies, or to stop it accepting Cookies from a particular website. However, if you disable all Cookies we cannot tell if you are signed in and some features of our Site may not work correctly and you may have to manually adjust some preferences every time you visit. See our cookies policy for more information.

All modern browsers allow you to change your cookie settings. You can usually find these settings in the Options or Preferences menu of your browser. To understand these settings, the following links may be helpful, or you can use the Help option in your browser for more details.

If you wish to check and manage third party advertising cookies, you can turn these off by going to the Your Online Choices site.

To find out more about cookies visit www.aboutcookies.org or www.allaboutcookies.org.

Updates

We may occasionally update this policy. We encourage you to periodically review this policy for the latest information on our privacy practices.

Information for European Union Citizens and Residents

If you are not happy with the way we are using your personal data or how we facilitate your rights or comply with our obligations under applicable data protection law, you have the right to make a complaint to the Irish Data Protection Commissioner by emailing info@dataprotection.ie.