Privacy Policy

At Varisource, Inc (“Varisource”), we respect your privacy and is committed to protecting it through our compliance with this policy in providing the website www.varisource.com and the associated software platform (collectively, the “Service”).  The policy (“Policy”) describes how we collect, use and disclose Personal Information, and to inform you of your rights with respect to such Personal Information.
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 APPLICABILITY OF PRIVACY POLICY
This Privacy Policy relates to “Personal Information”, meaning information about an identifiable individual, whether, for example, that individual is our Customer, or our Customer’s provisioned user or an individual whose information is part of Processed Data, as these terms are defined below. Whether a person is “identifiable” means that they can be identified by the information itself or by that information combined with other information reasonably available.
This Privacy Policy applies to Personal Information collected or managed by Varisource through the use of the Service, data source integrations, and our websites. This Privacy Policy is also intended to explain how we use information which is not identifiable (and thus not Personal Information) that is collected via our websites and the Service.
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“Customer” refers to the customers of Varisource and their provisioned users.

“Customer Information” refers to information about our Customers and their provisioned users.

“Processed Data” refers to information that is processed by Varisource on behalf of our Customers through their use of the Service.

Varisource does not have a direct relationship with many of the individuals whose Personal Information is included in Processed Data. This privacy Policy is intended to provide information about how all Personal Information is collected, used, disclosed, processed and protected by Varisource.


DATA SOURCE INTEGRATIONS
The Service provides Customers and their provisioned users the ability to easily connect to a wide variety of data sources using data source integrations. Some of these third-party data source integration providers have terms and conditions particular to their data sources and, by making use of the data source integrations offered by Varisource, you acknowledge and agree that your use of the Service may be subject to terms and conditions of those third-party providers.

 CLASSIFICATION OF INFORMATION
When the Service is used by our Customers, we classify the Personal Information we collect, use and disclose into two main categories: The first is Personal Information included in Customer Information, and the second is Personal Information that is included in Processed Data. It is important to note that not all Customer Information or Processed Data is Personal Information, either because it relates to a company or a business, or it is not identifiable.


PROCESSED DATA
Varisource does not control what information a Customer chooses to include in Processed Data. Because we are unable to determine whether it is Personal Information or other information, we treat it as though it may be Personal Information but our Customers are entirely responsible for any Personal Information they choose to include in Processed Data. All Customers and their provisioned users should understand that data in Varisource can be exported, shared or displayed by a Customer or provisioned user. Customers and provisioned users are solely responsible for the use of such exported, shared or displayed data and for protecting it appropriately.


WHAT INFORMATION WE COLLECT
From our Customers, we only collect Customer Information that is necessary to establish and maintain the provision of the Service to them, as well as to understand and improve the usage and performance of the Service. When our Customers are corporations, as opposed to individuals, this information is not “Personal Information”. This Customer Information includes:
1. Customer name
2. Contact information, including postal and email addresses
3. Billing address
4. Billing details (as necessary for our internal accounting purposes and for processing payments through our contracted processing service)
5. Login information for provisioned users, such as usernames and encrypted passwords
6. Information about how the Customer and its provisioned users use the Service, including information about the Customer, location information, usage patterns and intended use of the Service.
7. Information provided by the Customer and its provisioned users in connection with any support given by the Varisource team related to the Service.
8. Login information for third party integrations to Varisource, such as usernames and encrypted passwords
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In connection with our marketing, sales and Customer support functions, we may collect publicly-available information about our Customers and provisioned users, which is used for the purposes set out in this Privacy Policy.

PURPOSESFOR COLLECTION
Processed Data is processed by Varisource on behalf of our Customers to provide them with the Service. Individual provisioned users whose Personal Information is contained in Processed Data should refer to the Customer’s privacy policy for an understanding of how Personal Information is collected, used, disclosed and otherwise processed by the Customer by use of the Service.

DISCLOSURE OF PERSONAL INFORMATION
Varisource may share Personal Information with people within the company who have a “need to know” the information for business or legal reasons, for example, in order to carry out an administrative function, such as processing an invoice or supporting questions that you have submitted to Varisource. We may share Personal Information with third parties, including:
1. Government and regulatory authorities, for example to respond to a legal request or comply with a legal obligation, in which case we will make reasonable efforts to give the relevant individual notice of the disclosure, provided we are able to identify the individual and are lawfully able to do so;
2. for the purposes of seeking legal or other professional advice; and
3. in the event that we sell, buy or merge any business or assets, including to the prospective seller or buyer of such business or assets and their respective professional advisers.
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We may also share anonymous or de-identified information with other third parties in connection with the purposes outlined in this Privacy Policy.

RIGHT OF ACCESS
Pursuant to applicable law, you may have certain rights in relation to your Personal Information, including a right of access. If your Personal Information is apart of our Customer’s Processed Data, you should seek this access from the relevant Customer. If we control the Personal Information, we may require additional information to confirm your identity, which will only be used for that purpose.

INFORMATION COLLECTED VIA OUR WEBSITE ANDOUR APPLICATION
When you visit our websites, www.varisource.com, we may use cookies, pixel tags, analytics tools, and other similar technologies to help provide and improve our services to you, and as detailed below:
1. Cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the website, pages visited, language preferences, and other web traffic data. We use the information for security purposes, to facilitate online navigation, to display information more effectively, to personalize your experience while using the website, and to otherwise analyze user activity. We can recognize your computer to assist your use of the website.
2. We also gather statistical information about the usage of the website and application in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding the website and application. Cookies may further allow us to select which of our advertisements, features or offers are most likely to appeal to you and to display them to you. We may also use cookies in online advertising, features or offers to see how you interact with such advertisements, features or offers and we may use cookies or other files to understand your use of other websites.
3. If you do not want information to be collected through the use of cookies when using our website or application, there is a simple procedure in most browsers that allows you to automatically decline cookies or gives you the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. However, if you do not accept these cookies, you may experience some inconvenience in your use of the website or application. For example, we may not be able to recognize your computer, and you may need to log in every time you visit the website or application.
4. Pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with our website to, among other things, track the actions of users of the website and other means of communication with you (including e-mail recipients), measure the success of our marketing campaigns, and compile statistics about usage of the website and response rates.
5. Analytics tools: We use website and application analytics services provided by third parties that use cookies, JavaScript and other similar technologies to collect information about website or application use, perform data enrichment and to report patterns or trends. The third parties that provide us with these services may also collect information about your use of third-party websites. These analytics providers may store this analytics data in the United States and other locations.

SAFEGUARDING PERSONAL INFORMATION
We are required by law to safeguard the Personal Information in our custody or control. We use industry standard measures to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. We protect Personal Information regardless of the format in which it is held. Our methods of protection include: (a) physical measures, such as restricted physical access to the systems delivering our Service; (b)organizational measures, including employee training and limiting access on a “need-to-know” basis; and, (c) technological measures, including the use of passwords and encryption. We use service providers, including our data hosting provider, to facilitate providing the Service. We use contractual means to make sure that our service providers only deal with Personal Information on our behalf to provide the Service and not for any other purposes. We also undertake diligence to satisfy ourselves that our service providers will implement adequate safeguards to protect Personal Information. If we have reason to believe that there has been a breach of security safeguards that has resulted in the inappropriate loss or disclosure of Personal Information, we will take reasonable measures to notify the affected Customers, as applicable, promptly and with sufficient detail to enable them to evaluate the breach and understand the likely consequences.

UPDATES TO THIS PRIVACY POLICY
Varisource may update this Privacy Policy from time to time. If it is updated, the effective date of the revision will be shown at the top of the Privacy Policy as the Last Updated date. In the event of a significant revision, Customers may receive notification by email or through the Service itself. All Personal Information collected after that revision date will be subject to the updated Privacy Policy.

ANONYMOUS INFORMATION
Varisource may use de-identified and/or aggregate information derived from Personal Information, for any purposes, including:
1. Analytics to understand how our Customers and, their provisioned users make use of the Service and our website and to make targeted offerings of certain Services to our Customers and provisioned users;
2. Information used to determine how to make improvements to the Service and to develop new features, capabilities and ways of presenting data; and
3. For commercial purposes, either for Varisource or for others. We will take industry standard steps so that this de-identified and/or aggregate information cannot be connected to any particular individual.

CONTACT INFORMATION
If you have any questions or comments about this Policy or our privacy practices, please contact us at: support@varisource.com