Privacy Policy – Orange Vest

Orange Vest Technologies Inc. (collectively with any subsidiaries and affiliates, “Orange Vest”, “OV”, “Company”, “we”, “us”, or “our”) values the protection of your privacy and maintaining your trust in our services. This Privacy Notice considers various laws such as the EU General Data Protection Regulation 2016/679 (“GDPR”), the California Consumer Privacy Act (“CCPA”), and the Australian Privacy Principles, as well as other data protection and security frameworks.

What is Personal Data

“Personal Data” means any data or information in any media that on its own or when combined with other data could identify a particular individual, or any other data or information that constitutes personal data under applicable law. Examples of Personal Data include an individual’s combined first and last name, home address, telephone number, fax number, email address, social security number or other government-issued identifier (including state identification number, tax identification number, driver’s license number, or passport number), geolocation information of an individual or device, biometric data, medical or health information, and credit card or other financial information (including bank account information). Personal Data also includes cookie identifiers associated with registration information, or any other browser or device specific number or identifier not controllable by the end user, and web or mobile browsing or usage information that is linked to the foregoing.

Personal Data does not include information that is de-identified, aggregated, or anonymized as defined by applicable law.

Scope

This Privacy Notice describes how Orange Vest uses and protects Personal Data collected through:

our websites: www.orangevesttech.com, www.orangevestapp.com, and any other Orange Vest websites on which this Privacy Notice appears (“Sites”);
Offline communications such as phone calls or site visits (“Offline Communications”);
conferences and events (“Events”); and
our social media, online products, learning tools, and services such as stories and forums (“Services”).

This Privacy Notice also explains our marketing practices generally.

Orange Vest Application

This Privacy Notice may apply to Orange Vest’s software-as-a-service products, including the licensed software available through our platform via https://orangevestapp.com, and any software, mobile applications, products, devices, or other services (collectively “Orange Vest App”).

For much of the Personal Data processed through the Orange Vest Application, we act as a processor/service provider and will only process such information on behalf of and in accordance with the instructions of our customers. Use of the Orange Vest Application is governed by a separate agreement, including an executed data protection agreement as applicable (“Subscription Agreement”), that covers the use and processing of data provided by users, which may include Personal Data, as well as other information or documents uploaded into the Platform (“Platform Content”). The customer (e.g., your employer or another entity or person) that entered into the Subscription Agreement with Orange Vest Technologies controls its use and access of the Orange Vest Application (their “Instance”) and any associated processing of Application Content. If you have been granted access to the Orange Vest Application as a user, please contact the customer whose Instance you are using for questions regarding Application Content.

By using the Sites, Orange Vest Application, or otherwise giving us your Personal Data through our Services, Events, or Offline Communications, you agree to the terms of this Privacy Notice.

Personal Data We Collect

We may collect Personal Data in several ways, including from you directly, automatically when engaging our Sites or Orange Vest Application, or through third parties.

Information You Provide to Us Directly

We may collect information directly from you when you engage with the Sites and set up accounts, sign up for or engage in any of our Services, register for Events, contact customer support via telephone or email; engage with our social media platforms or other Services, visit our offices, or otherwise contact us. The information we may collect includes:

your name, phone number, and other contact details, including the company you work for, for example when filling out a request via the Sites or for Services, Events, or Offline Communications;
your username, password, and email when you register for an account to interact with portions of the Sites;
photos or videos you submit;
the profile information you provide us when you create your account profile to use certain areas of the Sites or Orange Vest Application;
information you provide to attend Events;
information you provide for technical support or customer service requests including via chat, email or Offline Communications;
if taking a course on a Orange Vest Training or Demo, the course(s) you complete and duration you spent on the Site;
site tools such as cookies;
any information that you upload to the Sites and/or input into your account, including comments, forum posts, testimonials, or blog entries that you may provide via our Sites or for Services, which may be visible to other users of our Sites; and
any other information you may provide to us voluntarily through your use of our Sites, Services, Events, or Offline Communications including referrals, questions, or other details.

Instance Information: When we create or update an Instance, the Customer may provide us with account information associated with the Instance, such as email address, business address, phone number, password, domain, and similar account details or any combination of the previously mentioned. This information may also include credit card or other financial account information in connection with an order to purchase a subscription to the Orange Vest Application. Orange Vest Technologies utilizes credit card payment processors for credit card purchases. Orange Vest Technologies does not store credit card information other than confirmation that a credit card payment was made. We collect contact and account information from you that we pass through to the payment processor to facilitate the transaction. Other purchase order financial information may be collected and stored in our systems. We use this information for account management and billing purposes.

Information We Collect Automatically

We automatically collect information regarding the actions you take on the Sites and Orange Vest Application. This type of usage data helps us understand trends in our users’ needs so we can better consider new features or otherwise tailor the Sites and Orange Vest Application. We may share this usage data with third parties for legitimate business purposes, including to help us better understand our customers’ needs and improve the Sites and Orange Vest Application. Some examples of the usage data we may collect include:

the type of Web browser you use;
device type;
log or site access data;
your operating system;
your web request;
your Internet Service Provider and cookies;
location data, such as your IP address;
referring/exit pages and URLs;
the pages you view and how you interact with links;
the time and duration of your visits to the Sites or use of the Orange Vest Application; and
other information relating to your devices and your activity on the Sites and Orange Vest Application.

We may store such usage data itself and such information may be included in databases owned and maintained by Orange Vest Technologies affiliates, agents, or service providers. We may use such information and pool it with other information, for example, to track the total number of visitors to our Sites or users of the Orange Vest Application, or each page of our Sites, etc. We use this information to help us understand how people use the Sites and Orange Vest Application and to enhance our Services.

Our mobile application for the Orange Vest Application may collect certain additional information automatically, including the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, available storage space, connection type (e.g., WiFi vs. cellular), and information about the way you use the application. We may also use GPS technology (or other similar technology) to determine your current location. If you do not want us to have your location information, you should turn off location services for the mobile application located in your account settings or in your mobile phone settings or within the mobile application.

We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded. We link certain information we store within the analytics software to authorized users for customer usage and metrics, and to aid in customer success.

Tracking Technologies

Cookies and Web Beacons: We may use cookies (a small text file placed on your computer to identify your computer and browser) and web beacons (a file placed on a website that monitors usage) to improve the experience of the Sites and Orange Vest Application, such as pre-populating your username for easier login, to allow user-specific messaging, or to permit user-specific advertising.

We classify cookies in the following categories:

Strictly Necessary Cookies,
Performance Cookies,
Functional Cookies, and
Targeting Cookies.

You can opt out of each cookie category (except strictly necessary cookies) by clicking on the “Cookie Settings” button below:

Cookie Settings

You can remove persistent cookies and change your privacy preferences by following directions provided in your Internet browser’s “help” directory, or by clicking the Cookie Settings button above. However, certain features of the Sites or Orange Vest Application may not work if you delete or disable cookies. Some of our service providers may use their own cookies and web beacons in connection with the services they perform on our behalf, as further explained below.

We and our partners use similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level.

Third-party Technologies: Third parties, such as ad servers, ad networks, and data exchanges (“Advertisers”) may place or recognize a unique cookie on your computer or use other technologies such as web beacons so that they can tailor their advertisements to your apparent interests and deliver those advertisements to you while you are on our Sites. In addition, Advertisers use technologies (such as cookies, pixels, and web beacons) to collect information about your browsing behavior on our Sites which they may match with information they have previously collected. Our Privacy Notice does not cover any use of information that Advertisers may collect from you or that you choose to provide to them. For information about how to opt out of receiving certain behavioral advertisements, please visit this website (or this one if located in the European Union). Please note this does not opt you out of being served ads. You will continue to receive generic ads.

Social Media Widgets: Our website includes social media features, such as the Facebook Like button, and widgets, such as the “Share this” button or interactive mini-programs that run on our website. These features may collect your Internet Protocol address, which page you are visiting on our website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy statement of the company providing the features.

Do Not Track: At this time, Orange Vest Technologies does not recognize automated browser signals regarding tracking, including “do-not-track” signals.

Information from Other Sources

We may receive information about you from other sources, including your company or third parties who are Orange Vest Technologies customers or users or both, and combine this data with information we already have about you. If others give us your information, we will only use that information for the purpose of providing, supporting, and improving Orange Vest Technologies services and in compliance with the specific reason for which it was provided to us ( for example, as part of a referral of marketing campaign). The types of Personal Data we may collect include:

name, phone number, and other contact details, including the company for which you work.

How We Use Your Personal Data

We may use your Personal Data for the following purposes:

creating an account;
provision and monitoring of the Sites and Orange Vest Application to provide you with access to and to support the security of the Sites and Orange Vest Application;
providing you with a newsletter subscription;
surveys and other special offers. From time to time, we may offer our users the opportunity to participate in surveys and other special offers. If you elect to participate in these services, you will need to provide certain Personal Information;
questions and requests. If you contact us by email or otherwise, we will use the Personal Data you provide to answer your question or resolve your problem;
contacting you about other Products, Services, and Events – Orange Vest Technologies and, if you opt in, third parties may use your Personal Data to contact you in the future to tell you about products, services, and events that may be of interest to you;
marketing, research, and data analysis. In an ongoing effort to better understand and serve the users of the Sites and Orange Vest Application, Orange Vest Technologies may conduct research on its Customers’ and users’ demographics, interests, and behavior based on usage data and other information provided to us;
Service improvement. We may use your Personal Data, aggregated Personal Data, and other information collected through the Sites and Orange Vest Application to help us improve the content and functionality of the Sites and Orange Vest Application
order fulfillment. We may use your Personal Data that you provide to fulfill any orders or request for Services you may place as offered by Orange Vest Technologies’ Sites and the Orange Vest Application;
testimonials. We display personal testimonials of satisfied customers on our Sites in addition to other endorsements. By posting a testimonial, you give your consent for Orange Vest Technologies to use your testimonial, along with your name, and company name in all media;
blog. Our Sites offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them;
administering online education;
providing customer service;
detecting, investigating, and preventing fraudulent transactions and other illegal activities; and
carrying out any other purpose described to you at the time the information was collected.

The Legal Basis for Processing Your Personal Data

Legal Basis for Processing Personal Data: If you are a visitor from the EEA, our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it.

However, we will normally collect Personal Data from you only where we have your consent to do so, where we need the Personal Data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, or for more details on our legitimate interests, please contact us using the contact details provided in the How to Contact Us section below.

Who We Share Your Personal Data With

Your Personal Data, such as your name or username, may be available to others, for example when you create a profile or submit public queries. This information may be accessed by users who use the Sites or Orange Vest Application and may be accessed by commercial search engines such as Google, Yahoo, and Bing to the extent that such engines are permitted to access the Sites or Orange Vest Application.

We may disclose your Personal Data to the following categories of recipients:

Orange Vest Technologies subsidiaries and affiliates who provide data processing services to us including customer support or marketing, or delivery of the Orange Vest Application;
service providers that we believe to be trustworthy and have privacy practices consistent with ours (“Service Providers”). For example, we contract with Service Providers to provide certain services, such as hosting and maintenance, accounting, data analytics, data storage and management, and marketing and promotions, most of which are located in the United States. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, to protect your Personal Data from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Data other than as specified by Orange Vest Technologies;
our business partners, such as integration partners, referral partners, reseller partners, event sponsors, ad partners, and marketplace partners, with whom you interact via Orange Vest Technologies.
law enforcement, public authorities, or legal counsel in response to lawful requests or court orders. Orange Vest Technologies will cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Data and any other content and information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to or comply with legal requests (including court orders and subpoenas), to protect the safety, property, or rights of Orange Vest Technologies or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law;
a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger, or acquisition of any part of our business, provided that we inform the buyer it must use your Personal Data only for the purposes disclosed in this Privacy Notice; and
any other person with your consent to the disclosure.

Forums, Public Profiles, and Chat Rooms

Please be aware that whenever you share information on a publicly available page or any other public forum on the Sites or Orange Vest Application, others may access that information. In addition, please remember that when you share information in any other communications with third parties, that information may be passed along or made public by others. This means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications.

Children’s Privacy

We do not knowingly collect Personal Data from children under the age of 13. If we become aware that we have inadvertently received Personal Data from a child under the age of 13, we will delete such information from our records.

Security

You should be aware that no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Sites, we cannot and do not guarantee the security of any information you transmit on or through the Sites.

In support of our data protection values, Orange Vest Technologies also engages in a responsible disclosure program. The program invites you to help bolster existing security measures and adapt to the ever changing threat environment. We use technical and organizational controls to safeguard data, but if you become aware of a vulnerability or of an error in disclosure of any personal or confidential data, you may contact us through our Contact Us page.

Data Retention

We will retain your information for as long as we have an ongoing business relationship with you or the business need to do so (for example: to comply with applicable law, tax requirements, or enforce our agreements).

When we have no ongoing legitimate business need to process your Personal Data, we may either delete or de-identify it, or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

International Data Transfers

Your Personal Data may be transferred to and processed in countries other than the country in which you are a resident. These countries may have data protection laws that are different from the laws of your country.

Specifically, our Sites are hosted in the United States and our group companies and Service Providers operate around the world.

We have taken appropriate safeguards to require that your Personal Data will remain protected in accordance with this Privacy Notice. For example, before transferring your Personal Data from the EEA to the United States, we will ensure that we have an appropriate mechanism for the international transfer in place, such as a data protection agreement with standard contractual clauses.

Third Parties/Links

Our Sites and Orange Vest Application may contain links or integrate with other websites and online services, or allow others to send you such links. Orange Vest Technologies is not responsible or liable for any damage or loss related to your use of any third-party website or online service. You should always read the terms and conditions and privacy notice of a third-party website or online service before using it, whether directly or in connection with your use of the Sites or the Orange Vest Application.

Your Rights

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to use some of our features. If we have collected and processed your Personal Data with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.

Please note that we may still use any aggregated and de-identified Personal Data that does not identify any individual, and may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.

We respond promptly to all requests we receive from individuals wishing to exercise their data protection rights, and at the latest within a month.

Cookies: You can accept or reject cookies for our websites through our Cookie Preference Center, accessible by clicking the “cookie settings” button. You can also do so by adjusting your web browser controls.

Marketing Communications: You can opt out of receiving promotional or marketing communications from us at any time by using the unsubscribe link in the email communications we send. To opt out of non-email forms of marketing, please contact us. If you set up an account on our Sites, we will still send you non-promotional communications like service-related emails.

We respond promptly to all requests we receive from individuals wishing to exercise their data protection rights, and at the latest within a month.

Upon request, Orange Vest Technologies will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Data.

Exercise your Rights

To exercise any of the rights as described in this section, please submit a verifiable request to us by contacting us through our Contact Us page.

Only you or someone legally authorized to act on your behalf may make a verifiable consumer request related to your Personal Data. You may also make a verifiable request on behalf of your minor child.

Rights for California

The California Consumer Protection Act (“CCPA”) protects a California resident’s right to request access to or deletion of their personal information, with exceptions. Orange Vest Technologies does not discriminate against the exercising of these rights.

The categories of data that we may use or share with third parties is described in the Personal Data We Collect, How We Use Your Personal Data, and Who We Share Your Personal Data With sections of this Privacy Notice. For business purposes, in the last twelve months, Orange Vest Technologies may have collected, used, and shared personal information about you as described there.

If you reside in California:

you have the right to request that we disclose the Personal Data we collect, use, disclose, and “sell” about you over the past 12 months; and
you have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions.

Once we receive and confirm your Verifiable Consumer Request we will delete (and direct our service providers to delete) your Personal Data from our records, unless an exception applies.

As a California resident, you also have the right to opt out of the sale of Personal Data.

Orange Vest Technologies does not sell Personal Data in the traditional sense, such as for monetary value. However, the CCPA provides a broad understanding of “sell” which can include sharing for non-monetary benefits. As this new law is still evolving, and in the interest of transparency, Orange Vest Technologies acknowledges that we may share or allow third parties to collect tracking technologies through our Sites or share contact information with event sponsors as described in the ways and purposes above, including for advertising and marketing. To exercise your “opt out of sale” rights please contact us at our Contact Us page.

For more information on CCPA and California privacy rights, please see our California Privacy Rights page.

California Shine the Light Law

Orange Vest Technologies does not share personal information to third parties for third-party direct marketing purposes. Cal. Civ. Code §1798.83(d).

Rights for European Economic Area (EEA) and Adequacy Countries

You have the following rights under the General Data Protection Regulation (GDPR) with respect to the information Orange Vest Technologies is the controller:

to access the Personal Data we maintain about you;
to be provided with information about how we process your Personal Data;
to correct your Personal Data;
to have your Personal Data erased;
to object to or restrict how we process your Personal Data; and
to request your Personal Data to be transferred to a third party.

You also have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA, Switzerland, and certain other countries (including the US) are available here.

Rights for New Zealand

You have the right to ask for a copy of any Personal Data we hold about you, and to ask for it to be corrected if you think it is wrong. If you’d like to ask for a copy of your information, or to have it corrected, please contact us by email.

If we receive a request for access to Personal Data, we will respond within 20 working days of receiving a verifiable request. Our response may include a decision about whether we will be able to provide the requested information. We may be able to withhold information if:

it is not readily retrievable;
releasing it could negatively affect the requestor’s mental health;
releasing it could put somebody else in danger;
releasing it would breach someone else’s privacy;
it was provided in confidence;
we do not hold any Personal Data about the requestor;
the request is trivial; or
the request is vexatious.

Rights for Australian Citizens

The Australian Privacy Principles (“APPs”) set out in the Privacy Act provide you the right to request access to, and correction of, the Personal Data we hold about you by contacting us using the contact details set out in the Privacy Notice.

For additional information regarding APPs, see the Supplementary Privacy Notice for Australia section.

Privacy Notice Changes

From time to time, we may change this Privacy Notice. When we do, we will take appropriate measures to inform you if necessary, consistent with the significance of the changes we make. For example, we may give you notice by posting the revised Privacy Notice on the Sites prior to the change becoming effective.

Any changes will go into effect on the last updated date shown in the revised Privacy Notice. You can see when this Privacy Notice was last updated by checking the “Last Updated” date at the top of this Privacy Notice. By using the Sites or providing information to us following such changes, you will have accepted the amended Privacy Notice.

Please print a copy of this Privacy Notice for your records.