Adopted: August 1, 2019; Updated: August 1, 2019
Voranda, Inc. and its subsidiaries, (“we,” “our” or “Voranda”) are committed to respecting your data protection rights under applicable privacy laws (we refer to any such rights as “data subject rights”).
YOUR RIGHTS EXPLAINED
Residents of some countries, including those in the European Economic Area, have data subject rights available to them under applicable data protection laws. These rights may include the right to request access to, or to request erasure or portability of, your personal information. You may also have a right to object to, or request that we restrict, processing of your personal information. Where such rights apply, we will comply with requests to exercise these rights in accordance with applicable data protection laws.
If you make a request to access personal information we hold about you (also known as an “access request”), we will provide the Digital Identifiers of your browser(s) and/or device(s) that we may store. Additionally, we may also provide you with certain other information that we may have stored and associated with your Digital Identifiers.
Please note, however, that we have a very short retention period for most files with Digital Identifiers that we store or process. As a result, we may not be able to provide you with any records at all in response to an access request. In such cases, however, we will inform you that we have not been able to locate any records associated with your Digital Identifiers.
Important Note: We have a responsibility to verify your identity before we respond to an access request. This is to make sure that we provide a copy of your personal information only to the person who is entitled to it — you. Because of this, it is our policy not to accept requests submitted by third parties (including automated robots), and to require certain documentation from you to verify that you are authorized to make the access request. If you wish to make an access request, we kindly ask that you contact us directly and follow the instructions below.
HOW TO MAKE A DATA SUBJECT RIGHTS REQUEST
If you wish to make a data subject rights request, please follow the steps described below:
Step 1: Locate Your Digital Identifiers
In order for us to locate relevant records, we will need you to provide us with your Digital Identifiers. You can find your Digital Identifiers as follows:
- Web Browsing
Please keep in mind that different cookies are placed on each browser and device that you use to access the Internet. As a result, if you use multiple browsers (for example, Google Chrome and Mozilla Firefox) and devices (for example, a laptop computer and a mobile phone), you will need to locate the applicable cookies for each browser and device.
- Mobile Devices
Additionally, certain mobile devices (for example, mobile phones or tablets using the iOS or Android operating systems) generate a persistent “Advertising Identifier” per device, which, among other things, can be used by third parties for purposes of providing you with targeted advertising. On iOS devices, your Advertising Identifier may be referred to as an “IDFA,” “IFA,” or an “ID for Advertising.” On Android devices, your Advertising Identifier may be referred to as an “Advertising ID.” Please follow instructions from your mobile device manufacturer on how to locate your specific Advertising Identifiers.
Step 2: Verify Your Digital Identifiers
In order to make sure that we are responding only to the person who is authorized to make the access request, we also will need some supporting proof to demonstrate that you are indeed connected to the Digital Identifiers you located in Step 1. For Digital Identifiers stored in cookies, please take a screenshot of each cookie, taking care to make sure that the screenshot shows both the name of the cookie and the full Digital Identifier. For Digital Identifiers located on a mobile device, please take a screenshot of a screen that displays the Digital Identifier. Additionally, please fill out, sign and include in your request the Authorization Verification Form that we have prepared, which attests that the Digital Identifiers you have located are indeed associated with you. By signing the form, you declare, under penalty of perjury, that all statements made on the form are true, and you must also have a witness sign and date the form. By the signing the form, the witness declares, under penalty of perjury, that your signature on the form is genuine. In addition, you and the witness must each provide a copy of one identifying document, such as a passport or driver’s license. The names on the document copies must match the printed names on the Authorization Verification Form. We require these steps to help us verify that you, as the data subject of the personal information you have requested, are authorized to request and receive such personal information.
Step 3: Contact Us
Once you have located your Digital Identifiers and can provide us with verification of those Digital Identifiers as instructed above, please contact us with details of the data subject rights you wish to exercise. The easiest way to do so is to email us at email@example.com. Your completed Authorization Verification Form and required documentation must be attached to the email as PDF files. Please make sure to include the following information in your email:
- Your full name
- The country in which you are located at the time you are making your request
- The data subject rights you wish to exercise
- A full list of your Digital Identifiers
- Supporting proof, as described in Step 2
- A signed Authorization Verification Form (with witness signature), linked in Step 2
- The identity documents described in Step 2.
You can also make a data subject rights request by postal mail, by sending a written request with all of the above-listed information to the following address:
650 Castro Street #120-275
Mountain View, California 94041, USA
Important note: The data controller of European Economic Area residents’ personal information is Voranda, Inc., at the above address.