Visage Privacy Policy

Visage Mobile, Inc. Privacy Policy

The purpose of this Privacy Policy is to describe the practices employed by Visage Mobile, Inc. (“Visage”) with respect to the acquisition, receipt, use, and protection of the information we receive from and on behalf of our customers, prospects, and partners.

Visage adheres to the Safe Harbor Privacy Framework between the United States Department of Commerce and the European Commission with respect to Personal Data that is transferred from the European economic area to the United States, and has certified its compliance to the US Department of Commerce. For further information about the Safe Harbor Privacy Framework and the documents that comprise its requirements, see the U.S. Department of Commerce website at http://www.export.gov/safeharbor/.

 

Information Collected and Intended Use

Visage provides enterprise mobility management solutions. In the performance of this service, the information we receive from our customers may contain one or more of the following data elements which is considered personal information related to the employees of our customers: Employee Id, Name, Title, Location, Corporate E-Mail Address, Department/Cost Center, Phone Numbers, and Corporate Address. Additionally, we receive Telecommunication Invoices including carrier billing reports associated with devices, services, and networks for which Visage customers are either primarily or secondarily liable.

This information is used for the purpose of matching charges and telecommunications inventory to the appropriate employee and/or cost center within Visage’s corporate customer enabling the customer to actively supervise the deployment, use and expense of its telecommunications and mobility resources.  We also aggregate our customer’s data and use it to identify market trends and insights that we may share with third parties.  When using the data in this manner we assure anonymity by first removing any personal identifiable information, including the identity of the individual’s employer.

In addition, parties visiting our website (www.visagemobile.com) can visit the site without providing personal information; however, computers connected to the internet contain information such as IP Address (Internet Protocol Address), and domain names that identify the computer and network used to access our web site. This information is captured and stored solely for tracking and monitoring purposes.

To develop content targeted to your interests, we use aggregated user information to determine which areas of our website users prefer based upon traffic to those areas. We do not track what individual users read, but instead how many pages or content areas are viewed.

To enhance your experience we may provide you with interactive communications, such as our electronic newsletters, to the e-mail address that you provide to us. Such interactive communications are provided only to those users who have expressly provided us with their permission to receive them as part of their user profile.

From time to time we may provide e-mails highlighting new features, promotions or contests on the website to those users who have expressly provided us with their permission to send such communications as part of their user profile.

We respect the privacy of our users and shall not disclose or distribute our user list to any third party, nor shall it permit anyone else to do so.

Users may change their user profile to stop receiving newsletters or marketing material from Visage. Users may choose to stop receiving such communications at any time by clicking the ‘unsubscribe’ link located at the bottom of all non-operational emails from Visage.

Visage’s adherence to seven Safe Harbor principles

Visage handles Personal Data in accordance with our Safe Harbor Privacy Policy, which is based upon the seven principles identified in the Safe Harbor Privacy Framework.

Notice

When Visage receives Personal Data for processing, we are acting as an agent for our customers and do not provide notice to individuals regarding the collection and use of their personal data. Our customers remain responsible for providing notice, if and to the extent they believe such notice is necessary under applicable EU law.

Choice

When Visage receives Personal Data from individuals in the European Union pursuant to instructions of our customers, we are acting as an agent for our customer and do not provide choice to individuals regarding the collection and use of their personal data. Our customers remain responsible for providing choice, if and to the extent they believe such choice is necessary under applicable EU law.

Onward transfer

Visage does not transfer Personal Data to unrelated third parties, unless lawfully directed by a customer client, or in certain limited or exceptional circumstances in accordance with the Safe Harbor Privacy Framework.

In the event that Visage ever needs to transfer Personal Data to an unrelated third party, Visage will ensure that such party is either subject to the Safe Harbor Agreement, subject to similar laws providing an adequate and equivalent level of privacy protection, or will enter into a written agreement with the third party requiring them to provide protections consistent with the Safe Harbor Privacy Framework and Visage’s Safe Harbor Privacy Policy. Should Visage learn that an unrelated third party to which Visage has transferred Personal Data is using or disclosing Personal Data in a manner contrary to this Policy, Visage will take reasonable steps to prevent or stop the use or disclosure.

Security

Visage is committed to the security of all personal data. Visage employs standard industry practices to protect customer information from loss, misuse, unauthorized access, disclosure, alteration and destruction of information.  Visage also use reasonable means to ensure that it complies with confidentiality and non-disclosure obligations set forth in agreements between Visage and its customers, partners, suppliers, and employees.

Visage’s hosted solutions maintain customer information on secure servers located in secure data centers not under Visage’s direct control. Personal Data stored in databases requires unique login ids and passwords in order to access the information and is only used for the intent described in this policy. Customer login ids and passwords are provided to customers in order to allow access to the information pertaining to the specific customer for whom it is intended.

All servers are protected by one or more firewalls restricting access to the individuals for which access is specifically intended. Extensive monitoring and security tools are utilized to ensure confidentiality, integrity, and availability.

Data integrity

Visage does not modify or alter in any way Personal Data but preserves such data in its original form to the extent possible, consistent with any processing or necessary to fulfill the services requested by customers.

Access

Contract information and Personal Data are accessible only by those Visage employees and consultants who have a reasonable need to access such information in order for us to fulfill our contractual and legal obligations. All of our employees and consultants have entered into confidentiality agreements requiring that they maintain the confidentiality of Personal Data.

Due to the nature of the services Visage provides and security concerns, the burden, expense and security risks of providing individual access to Personal Data would be disproportionate with risks to the individual’s privacy in the case in question. Such access would risk violating the rights of persons other than the individuals seeking access and would increase the security risks. Therefore Visage cannot provide individuals with access to Personal Data in order to correct, amend, or delete information that is demonstrated to be inaccurate.

Enforcement

Visage assures compliance with this Safe Harbor Privacy Policy and the Safe Harbor Privacy Framework by utilizing the self-assessment approach. The self-assessment is conducted on an annual basis to ensure that all of Visage’s relevant privacy practices are being followed in conformance with this Safe Harbor Privacy Policy and the Safe Harbor Privacy Framework. Any employee that Visage determines is in violation of these policies will be subject to discipline, up to and including termination of employment.

Visage will also assure compliance with this Safe Harbor Privacy Policy and the Safe Harbor Privacy Framework by fully investigating and attempting to resolve any complaint or dispute regarding the use and disclosure of personal data in violation of this Privacy Policy.

For complaints that cannot be resolved by Visage and the complainant, we agree to dispute resolution using the American Arbitration Association as a third party resolution provider pursuant to the Safe Harbor Privacy Framework.

Questions

Customers or prospective customers of Visage with questions or concerns about Visage’s compliance with this Safe Harbor Privacy Policy may contact us by email at privacy@visagemobile.com with “privacy” in the subject line, or US Mail at:

Visage Mobile, Inc.
500 Sansome Street, Suite 300

San Francisco, CA 94111

ATTN: PRIVACY

Safe Harbor Privacy Policy updates

This Safe Harbor Privacy Policy may occasionally be updated. When material updates are made, the date of the last revision will be reflected at the end of the page. This page may be bookmarked to facilitate periodic review of this Safe Harbor Privacy Policy and to note recent updates.