Privacy Policy GENERAL TERMS Viaflex and all of its subsidiaries (collectively known as “Viaflex” for purposes of this privacy policy) values our team members, as well as your interest in our products and your visit to our websites. Viaflex places a strong emphasis on respecting team member and customer privacy. Viaflex recognizes the importance of maintaining the privacy of any personal data collected through any means. Therefore, we process any personal data collected in accordance with the legal provisions for the countries in which the personal data is received, kept, and maintained. This Privacy Policy applies to our use of any personal data provided to or collected by Viaflex and will explain how Viaflex uses the personal data we collect from you when you use our website. Topics What data do we collect? How do we collect your data? How will your data be used? How do we store your data & how long do we keep it? Sharing personal data Transfers of your personal data to other countries Recipients of the personal data Cookies & Similar Technologies Information Retention Policy Legal Basis for Processing personal data Your Information Protection Rights Exercising your rights Contact us Privacy policies on other websites Updates to this Privacy Policy California’s Shine the Light Law WHAT DATA DO WE COLLECT? Viaflex collects different types of personal data. Both outside and within the United States, Viaflex collects personal data belonging to its employees, contractors, suppliers, and customers that is relevant for the business purposes described below. This privacy policy also applies to all information collected by or submitted to Viaflex or its services via Viaflex’s website(s), including any information by which you may be personally identified, such as name, postal address, email address, telephone number(s), or any other information defined as personal or personally identifiable data under applicable law. Much of the personal data Viaflex collects is voluntarily provided by the employee or customer. The types of personal data Viaflex collects include, but are not limited to: Employment contact and identification details: name, home address, documents that verify address, phone number, mobile phone number, personal email address, driver’s license, other governmental identification information such as social security number, date of birth, age, number of children or dependents, race, country of domicile. Position description: title, division or subsidiary of employment, position held, start date, end date if past employee, performance reviews and assessments if applicable. Employee and customer access or use information: username and passwords to log into a customer portal, location data, other website or product access information, use of corporate credit card (aka “P Card”), the division or subsidiary with which business is conducted, purchase order information including delivery addresses and phone numbers. Financial information: voided check or banking information for opt-in direct deposit payment option, salary and bonus plan payouts, 401K contributions and employer match, benefit contributions, payment history, bank or investment account. Medical information: Viaflex provides a counselor and physician’s assistant services, free of charge, to its Team Members. The counselor or physician’s assistant may collect various health related information from a Team Member for the purposes of providing their service(s). Additionally, Viaflex provides health insurance to many of its team members through a third-party health insurance provider. Viaflex and that provider may collect health related information to perform those services. Internet Protocol (IP) addresses: Viaflex collects the IP addresses that visit our websites, but we do not link the IP address to any particular consumer or household and could not reasonably link the IP address with a particular consumer or household. Under certain privacy laws, such as the California Consumer Privacy Act (“CCPA”) this collection of IP address is not considered “personal information.” In order to optimize our services to you and continually improve our products, we may ask you for information about your personal or professional interest, demographic background, your experiences with our products and services, as well as more detailed information pertaining to our contact with you. We may also use your IP address for some of our website services. Information on the “cookies” that we use and their features can be found in our Cookies section below. Personal data does not include information that is not identified or identifiable to a natural person, or information that has been stripped of all identifiers such that an individual cannot be identified or re-identified. HOW DO WE COLLECT YOUR DATA? You directly provide Viaflex with most of the data we collect. We collect data and process data when you: Register online or place an order for any of our products or services. Voluntarily complete a customer survey or provide feedback on any of our message boards or via email. Use or view our website via your browser’s cookies. HOW WILL YOUR DATA BE USED? Viaflex recognizes and respects the interested person’s legal rights, such as, among others, the right to access his/her own personal data, the right to obtain the updating rectification or integration of data, the right to cancel the data in cases provided for by applicable laws. Viaflex will use your personal data only to the extent it is compatible with the following purposes: For legitimate business purposes and objectives (including, but not limited to, providing services, financing, customer support, product safety, marketing, promotions, and recruitment of employees) in compliance with the principles of relevance, pertinence, and utilizing processing methods adequate to such objectives (e.g. to provide you with password reminders or to notify you that a particular service has been suspended for maintenance); For compliance with processes and procedures provided for by Viaflex’s system for protection of company data, according to which all data is classified in order to determine and perform necessary security measures; For service administration purposes, which means that Viaflex may contact you for reasons related to the service you have signed up for. More particularly: Employee Information:To identify current or potential employees and some past employees; To pay that employee; To provide employment benefits to that employee: such as a retirement 401K, health, dental, vision, etc.; To track that individual’s relation to Viaflex such as applicant, employee, former employee and all potential statuses of such, e.g., retired, quit, terminated. Customer Information & Service: To provide, personalize, improve, update and expand our services, which may include: Authenticating your access to the services and improving Viaflex technological security; To fulfill orders for products or services, and for other services related to your order such as product delivery, maintenance, warranty service, financing, leasing, and credit services; Processing your payments for products and/or service subscriptions or features; Provide support to products, product improvement, diagnostics and repairs, product safety or recalls; Building new and improving existing products and services; Conducting scientific or statistical research; or Enforcing our Terms and Conditions. Communications: We use your personal data to communicate with you about the services such as when we: Respond to your inquiries to member services; Inform you of product changes or updates, or new products and services; Provide you with information or request action in response to technical, security, and other operational issues; or To provide you with marketing, communications, and offers for products and services from Viaflex or our distributors or suppliers. Marketing: We use your personal data to better manage our everyday business needs such as payment processing and financial account management, product development, product safety, contract management, website administration, web-forum management, order or contract fulfillment, analytics, fraud prevention, corporate governance, reporting and legal compliance. Viaflex may use your personal data to send you information about our products and services that we think you might like. You may always opt-out of receiving these marketing materials at any time. If you no longer wish to be contacted for marketing purposes, please contact us via the information in the Contact Us section below. HOW DO WE STORE YOUR DATA & HOW LONG DO WE KEEP IT? Viaflex stores your personal data on secure on-site servers or secure cloud servers. These servers are further secured by administrative restricted, password protected precautions. Viaflex acquires and retains only the personal data that is required for effective operation of Viaflex or otherwise required by law. Access to such information is restricted internally to those with a recognized need to know. SHARING PERSONAL DATA Viaflex may share your personal data if we believe it is reasonably necessary to: Comply with valid legal process (e.g., subpoenas, warrants); Enforce or apply Viaflex’s Terms and Conditions; Protect the security or integrity of services; or Protect the rights, property, or safety, of Viaflex, our employees or users. Viaflex also uses various service providers to help us provide services to you. As a result, these partner companies will have some of your information in their systems. Our partner companies are subject to contractual obligations governing data security and confidentiality consistent with this Privacy Statement and applicable laws. These processing partners include our: Payment processors; Retirement Fund managers and providers; Health care, dental, and vision providers; and Remote access service providers. Viaflex does not sell or share any personal data with non-agent third parties. COOKIES & SIMILAR TECHNOLOGIES Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the cookie. Our website uses cookies to distinguish you from other users of our website and to collect information about your online preferences. This helps us to provide you with an optimal experience when you browse our website and also allows us to improve our site. We use cookies and similar technologies for storing and honoring your preferences and settings, enabling you to sign-in, combating fraud, analyzing how our products perform, and fulfilling other legitimate purposes. By continuing to browse the site, you are agreeing to our use of cookies. We also use “web beacons” to help deliver cookies and gather usage and performance data. Our websites may include web beacons, cookies, or similar technologies from third-party service providers. You have a variety of tools to control the data collected by cookies, web beacons, and similar technologies. For example, you can use controls in your Internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. Most internet browsers are automatically set up to accept cookies. However, you can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please note: if you use your browser settings to block some or all cookies you may not be able to access all or parts of our site. INFORMATION RETENTION POLICY We will retain your personal data for as long as you are employed by Viaflex or, if you are a Viaflex customer, for as long as you maintain an account or as otherwise necessary to provide you with Viaflex services. Viaflex will also retain your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Viaflex will hold your personal data on our systems for as long as is necessary for the relevant product, or service, or as long as is set out in any relevant contract you have with Viaflex or Viaflex’s data retention schedule. Viaflex will maintain personal data for as long as necessary to fulfill the purposes outlined in this document and per record retention requirements at the federal, state, and member state level based on the category of personal data processed. Viaflex takes reasonable steps to ensure that personal data is accurate, complete, current, and reliable for its intended use. Where permissible, we will also delete your personal data upon request; please see the Contact Us information below to make such a request. Please note, however, that each request for deletion is subject to review by the Viaflex Legal Department; there may be certain circumstances in which we will have to keep and maintain the personal data even in light of your request. Viaflex will keep your personal data for only the period of time that is required for effective operation of Viaflex or otherwise required by law. Once this time period has expired, we will delete your personal data. WHAT ARE YOUR RIGHTS IN CALIFORNIA? California residents and workers are afforded the additional following rights under the California Consumer Privacy Act (“CCPA”): The right to opt-out – You have the right to direct a business to stop selling your personal data to a third party. (Please note that Viaflex does not sell personal data to third parties.) The right to non-discrimination – You have the right to non-discrimination if you choose to exercise any of your privacy rights under the CCPA. EXERCISING YOUR RIGHTS If you make a request regarding your personal data, we have one (1) month to respond to you. If you would like to exercise any of these rights, please contact us at: Email: [email protected] Call us at: (605) 335-0174 Or write to us: ViaflexAttn: Legal Department821 W Algonquin StSioux Falls, SD 57104 If you wish to be “forgotten,” please complete and provide the following form to help us efficiently remove your personal data from our system. The link to the form is: here. You also have the right to lodge a complaint with your supervisory authority. CONTACT US If you have any questions, comments, or concerns about how we handle your personal data or if you believe Viaflex is processing your personal data unlawfully, please contact us through our Support Team or write to us at: Email: [email protected] Call us at: (605) 335-0174 ViaflexAttn: Legal Department821 W Algonquin StSioux Falls, SD 57104 Privacy Policies on Other Websites Viaflex websites may contain links to other non-Viaflex websites. Our privacy policy only applies to Viaflex websites, so if you click on a link to another website, you should read their privacy policy. UPDATES TO THIS PRIVACY POLICY Viaflex keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated July 12, 2023. CALIFORNIA’S SHINE THE LIGHT LAW California Civil Code Section 1798.83, known as the “Shine the Light” law, permits Users who are California residents to request and obtain from us a list of what personal data, if any, we disclosed to third parties for their direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Request may be made only once a year and are free of charge. Under Section 1798.83, Viaflex currently does not share any personal data with third parties for our own direct marketing purposes.
