Vertalo, Inc

Privacy Policy

Effective: February 27, 2018

Scope

Vertalo, Inc (“Vertalo,” “we,” “us,” or “our”) provides this Privacy Policy because we know that you care about how your information is collected, used, shared, and retained.

Our website at https://vertalo.com/ (the “Site”) is available to the general public (“Site Visitors”) for informational and marketing purposes. We also provide a social networking and data storage platform (the “Platform”) at https://app.vertalo.com (or relevant corporate domain) that enables our registered Platform users (“Users”) to store important information regarding their credentials, qualifications, and employment (“Records”), and make certain choices on how, when, and where to share their Records (the “Platform Services”). As part of the Platform Services, other Users and Platform visitors (“Platform Visitors”) may store, share, view, supplement, and/or retrieve Records with certain limitations set by the User’s privacy settings (collectively, Site Visitors, Users, and Platform Visitors are referred to as “Participants”). Please note that in some cases Site Visitors may also be Users or Platform Visitors.

Consent

By visiting our Site or using our Platform, Participants agree to this Privacy Policy and the accompanying Terms of Use. Capitalized terms not defined in this Privacy Policy have the meaning ascribed to them in the Terms of Use.

Information We Collect and What We Do With It

I. Site

We collect and use the following information from Site Visitors when they interact or link from our Site:

Contact Information: We collect contact information from Site Visitors that e-mail Vertalo via the Contact Us link and/or sign up for our blog feed/update form:

• Contact Us: When contacting Vertalo, we will collect your e-mail address and its contents to provide the requested information, support, to enhance the Site or Platform, and put your e-mail on a contact list for future marketing messages to your inbox.
• Blog Feed/Update Form: By signing up for our blog or filling out our form to receive updates, you will receive our blog feed and other marketing messages to your inbox. See Direct Marketing in III. Platform and Site Generally below.

II. Platform

We collect and use the following information from Users and Platform Visitors, as applicable, when interacting with the Platform and/or using the Platform Services:

Account Profile Information: In order to become a registered User, a person must create an account profile on the Platform. To that end, we collect certain information such as the User’s name, e-mail addresses, an Ethereum address (also referred to as a ‘wallet ID’), phone number, and postal address. In the case of corporate accounts, additional information is collected such as business ID #, business category, admin addresses, etc. We’ll also keep a record of how often Users visits their profile, such as when logging into their account.

A User must initially authenticate itself to the Platform using a third party account. When using a third party account, Users authorize us to collect, store, and use, in accordance with this Privacy Policy, any and all information that the User has authorized that third party to provide. For example, in the case of a social media account, such information may include a User’s first and last name, profile image, e-mail address, birthdate, and/or gender. Where a User wishes to register an organization with us, the User must authenticate herself by demonstrating sufficient control of the organization’s web domain by some means (e.g., updating DNS records, deploying a special web page).

Platform Services: Users will be able to share and manage their Records so that they can easily share such information with other Users or Platform Visitors.

The Platform Services’ core component is the ability to have Users request other Users to ‘certify’ (or attest to the truth of) their Records. For example, a User may request a previous employer to certify that the User worked for that employer. If true, the employer would certify this Record and supplement it with other information where necessary. The employer (or any other certifying User) would be able to share such Records downstream to third-parties.

The Platform Services accommodate two types of Users: “Individual Users” and “Organizational Users.” An account for an Individual User provides access for a person. An account for an Organizational User provides administrative access for one or more agents of a company or other institution (academic, governmental, etc.).

Disclosure of Records generated by an Individual User is at the sole and exclusive discretion of the Individual User. The sum total of all Records associated with an Individual User are used to create a Private Profile that contains the entirety of that Individual User’s Records and is viewable solely by the Individual User and, in the case of particular Records, any Users (such as Individual or Organizational Users) that certified that particular Record. The Individual User accesses the Platform Services to designate those she would like to be included on her Public Profile, which is viewable by all Users.

Additionally, Users may, pursuant to their privacy settings, allow other non-certifying Users or Platform Visitors to view Records for potential employment or business opportunities generally.

Finally, Users may choose to give us access to their contacts to make it easy for them to do things like share and collaborate on their Records, send messages, and invite others to use the Platform. If a User allows such access, we’ll store those contacts on our servers for the User to use.

Billing Information: Any payments required by the Platform will use “Talos,” which is Vertalos’ digital token built on the Ethereum blockchain; such payments will originate from your Ethereum address.

III. Site and Platform Generally

We collect and use the following information from Participants generally across both the Site and Platform:

Direct Marketing: We may use a Participant’s personal information provided to us through the Site or Platform for direct marketing purposes, such as e-mails advertising our Platform Services.

A Participant may opt-out at any time from the use of the User’s personal information for direct marketing purposes, and/or the transfer of such personal information to third parties for direct marketing purposes by contacting us at privacy@vertalo.com. Please allow us a reasonable time to process the request.

Further, a Participant may manage receipt of marketing and non-transactional communications by clicking on the “Manage E-mail Preferences” link located on the bottom of any Vertalo marketing e-mail and following the instructions found on the page that the link brings the Participant to. A Participant cannot opt-out of receiving transactions e-mails related to their account or purchases.

Usage Data: We collect information about Participants regarding how they use our Site or Platform, such as actions Users take in their account profile on the Platform (like sharing, editing, viewing, and moving files or folders).

We also collect information from and about the devices Participants use to access the Site or Platform, such as through Google Analytics. This includes information such as IP addresses, the type of browser and device used, identifiers associated with such devices, and/or the web page visited before coming to our Site or Platform.

We may anonymize usage data and process it in aggregate form to operate, maintain, manage, and improve the Site or Platform. This aggregate information does not identify a Participant personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated statistics in order to describe our Site or Platform generally to current and prospective business partners and to other third parties for other lawful purposes.

Google Analytics: Like most organizations, we rely on Google Analytics when a Participant visits our Site or Platform. Google Analytics may use tracking technologies such as, but not limited to, cookies (see Cookie Data below) to collect information our behalf such as the Participant’s IP address, Internet service provider (ISP), browser type, operation system and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the website visited, number of links clicked while on the website, search terms, and other data. By accessing and using the Site or Platform, Participants consent to the processing of data about them by Google Analytics in the manner and for the purposes set out in this Privacy Policy.

For more information on Google Analytics, including how to opt out from certain data collection, please visit https://support.google.com/analytics/answer/6004245. Please be advised that if a Participant opts out of any service, the Participant may not be able to use the full functionality of the Site or Platform.

Cookie Data: We use technologies such as cookies and pixels to collect information from Participants (including personal information), which we process in order to provide, improve, protect, and promote our Site or Platform. For example, cookies help us with things like remembering a username for a User’s next visit to the Platform, understanding how Site Visitors are interacting with our Site, and improving them based on that information. Participants can set their browser to not accept cookies. Please consult your internet browser’s documentation for information on how to do this, such as by using your browser in private mode to block cookies However, if a Participant decides not to accept cookies, this may limit the Participant’s ability to use the Site or Platform.

Additional Uses: We may also use contact information, billing information, account profile information, and other information collected pursuant to this Privacy Policy to respond to general inquiries, solicit feedback regarding our Site or Platform and support, provide relevant content on our Site or Platform including advertisements, communicate with Participants via e-mail regarding our current and future services, and administer our promotional programs.

How does Vertalo share information?

To the extent not mentioned above, we may share information collected from Participants (or Site Visitors or Users individually) as follows:

Other Users: Our Platform displays information such as Users’ name, profile picture, and e-mail address to other Users (and, depending on a User’s privacy settings, Platform Visitors) in places like a User account profile and sharing notifications. We may also connect Users that provide e-mail addresses from the same organization or company.

Other applications: The Platform will allow third parties to create apps that leverage Records and account profile information in innovative new ways. Users can give third parties access to their Records and account profile information in order to gain access to such apps - Just remember that their use of your information will be governed by their privacy policies and terms.

Governmental Access Requests: Vertalo may be required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

Corporate Restructuring: In the event of a merger, reorganization, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy. This Privacy Policy shall be binding upon Vertalo and its legal successors in interest.

Other Important Privacy Information

Security: Vertalo takes the security and privacy of the personal information that it collects pursuant to this Privacy Policy very seriously. Accordingly, we will implement reasonable and appropriate security measures to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations.

Access to Personal Information: Users can access their personal information by logging into their account within the Platform. If a User deletes its account (or requests that we delete the account), we will comply. However, please note: (1) there might be some latency in deleting this information from our servers and back-up storage; and (2) we may retain this information if necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.

Upon request to privacy@vertalo.com, we will provide Participants with confirmation as to whether we are processing their personal information, and have the data communicated to such Users within a reasonable time. Users have the right to correct, amend, or delete their personal information where it is inaccurate or has been processed in violation of this Privacy Policy. We may require payment of a non-excessive fee to defray our expenses in this regard. Please allow us a reasonable time to respond to your inquiries and requests.

Data Storage and Transfer: Our database servers are located in the European Union and will be accessed by Vertalo located in the Cayman Islands, and our affiliate SeriesX.net, Inc. (“SeriesX”) or other service providers located in the United States or other countries. SeriesX will access and process Participant’s data held in our European Union servers from the U.S. pursuant to SeriesX’s E.U.-U.S. and Swiss-U.S. Privacy Shield certification. SeriesX’s Privacy Policy is located here.

Except in the case of data transfers under an applicable E.U.-U.S. Privacy Shield Framework and/or Swiss-U.S. Privacy Shield Framework, the Participant’s decision to provide data to us, or allow us to collect such data through the Site or Platform, constitutes the Participant’s consent to data transfers from its country of origin to other countries.

Retention of Personal Information: We will retain a Participant’s personal information in a form that identifies the Participant only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing the Participant’s personal information for longer periods, but only for the time and to the extent such processing reasonably services the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. After such time periods have experienced, we may either delete the Participant’s personal information or retain it in a form such that it does not identify the Participant personally.

California Residents: We do not monitor any opt-out or do not track mechanism, including general web browser “Do Not Track (DNT)” settings and/or signals.

Children’s Online Privacy Protection Act (COPPA): We do not knowingly collect any personal information from children under the age of thirteen through the Site or Platform. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information to us. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at privacy@vertalo.com and we will endeavor to delete that information from our databases.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time, and will post any changes as soon as they go into effect. By accessing and using the Site and/or the Platform after we post any changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

Contact Vertalo

Have questions or concerns about Vertalo, our Site/Platform, and/or privacy? Contact us at privacy@vertalo.com.