POLICY VESPERA GENERAL DATA
PRIVACY POLICY Number-Version: 2.0____
Approved: Effective Date: October 22, 2024 Supersedes: _
PURPOSE
Vespera Life, LLC (“Vespera”) (also referred to as “we”, “us”, “our”) collects and uses personal data to provide world-class services for our employees, clients, and partners. This Policy is designed to set forth how Vespera will handle personal data that it collects in the normal course of business and when you use our website and services. Vespera strives to be global and consistent in how it handles personal data. Our privacy policy applies to:
1. All individuals who provide personal information, such as consumers, customers, research subjects, business partners, shareholders, job applicants, employees, retirees, and others;
2. All locations where we operate, even where local regulations do not exist; and
3. All methods of contact, including in person, written, via the Internet, direct mail, telephone, or facsimile.
This Policy describes Vespera’s standard global procedure governing access to and use of Vespera’s Personal Data across borders. Notwithstanding any limited application to Vespera’s industry, Vespera complies with such legislation as the Health Insurance Portability and Accountability Act of 1996, as amended, Subtitle A of Title V of the Gramm-Leach-Bliley Act, the Sarbanes–Oxley Act of 2002, and other privacy laws, rules, and regulations that may apply to Vespera, its employees, or its clients.
This Policy does not necessarily describe how local management may handle personal data in order to comply with local privacy laws. Local management in conjunction with the responsible human resources personnel will be responsible for accessing and complying with local/unique laws and/or rules regarding the processing of personal information in that particular locale.
This Policy is also designed to inform all employees about their obligation to protect the privacy of all individuals (including co-employees, independent contractors, or sub-contractors) and the security of their personal information. The violation of this Policy, whether negligent or intentional, will be subject to disciplinary action by Vespera.
SCOPE
This is a Global Policy.
DEFINITIONS
“Controller,” in this case, refers to Vespera and its authorized personnel, which determine the purposes and means of processing of Personal Data.
“Data Subject” in this case refers to any employee or third person (e.g., consultant or independent contractor) who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural, or social identity.
“General Business Purpose” means the Processing of Personal Data for any activity related to the commercial operations of Vespera’s worldwide organization. This could include, but is not limited to its sales, marketing, and research and development operations; protecting intellectual property; the provision of services; internal operations; and general employment matters, including recruitment both internally and externally. Data processing for General Business Purposes includes, but is not limited to, publishing global directories, maintaining files, payroll processing, managing benefit and medical plans, conducting performance reviews, and intra-company communications.
“Personal Data” means any information related to an identified or an identifiable person. For example, a Data Subject’s home address, e-mail address and/or phone number, personnel file, or benefits information would constitute Personal Data.
“Processor” means a natural or legal person, or any other entity that processes Personal Data on behalf of the Controller and under its control. In this context, a Processor may be a payroll preparation firm that works on behalf of Vespera and under its control. Vespera requires Processors to protect the privacy, confidentiality, and security of Vespera Personal Data.
“Processing” of Personal Data means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure, or destruction.
“Vespera” means Vespera Life, LLC.
“Sensitive Data” is a subset of Personal Data, and refers to any Personal Data pertaining to racial or ethnic origins, trade union membership, medical or health conditions, political or religious beliefs, sex life, criminal history, or other metrics.
“Third Party” means any natural or legal person, public authority, agency, or any other entity other than the data subject, the Controller, the Processor, and the persons who, under the direct authority of the Controller or the Processor, are authorized to process the Personal Data.
GENERAL
Vespera’s Global Data Privacy Policy (“Policy”) has been designed to comply with international Privacy Principles, where applicable.
How We Use and Safeguard Personal Data
A Data Subject’s Personal Data is initially maintained in his/her personnel file and/or entered into one of many appropriate databases; which are managed by Vespera’s local management staff. Thereafter, in the course of day-to-day business operations, authorized individuals within Vespera may from time to time utilize and/or transfer the Data Subject’s Personal Data among various Vespera personnel. These transfers of Personal Data are necessary in order to carry out Vespera’s General Business Purposes. To safeguard this Personal Data, and to comply with current legal requirements, Vespera has formalized and implemented a standard global procedure governing access to and use of Personal Data.
POLICY
Quality of Personal Data
Vespera will take reasonable steps that Personal Data and Sensitive Data are:
a. Obtained, where possible, directly from the Data Subject to whom the Personal Data relates;
b. Obtained and processed fairly and lawfully by Vespera for and General Business Purposes;
c. Relevant to and no more revealing than is necessary for General Business Purposes; and
d. Kept up to date to maintain data accuracy, while data are under the control of Vespera, and kept only for so long as is reasonably necessary.
Notice and Use of Personal Data
Vespera may inform Data Subjects what information we collect, how it is used, whether it may be temporarily transferred to others to provide the products or services requested and how to contact Vespera with privacy inquiries. Vespera’s use of Personal Data and Sensitive Data will be limited to General Business Purposes, and will not be kept longer than is necessary.
Individual Rights of Access to Personal Data
Vespera takes steps to make sure that the personal information it uses is correct. Vespera may allow Data Subjects reasonable access to Personal Data and Sensitive Data about themselves during normal working hours and upon reasonable request, and may be allowed to update and/or correct any inaccurate information.
Information We Collect
We may collect personal information such as your name, email address, phone number, and any other information you provide when using our services or website.
How We Use Your Information
We may use the information we collect to:
- Provide, operate, and maintain our services;
- Improve, personalize, and expand our services;
- Communicate with you, including customer service and support;
- Send you updates, marketing, and promotional materials.
Consent to Receive SMS Notifications
By providing your phone number, you consent to receiving automated Short Message Service (“SMS”) notifications from us for communication purposes. These messages may include updates, reminders, promotional content, or other information related to our services. You can opt out of receiving SMS messages at any time by following the instructions provided in each message. Text message and data rates may apply (to you) from your cellular telephone service provider.
The SMS opt in or phone numbers for the purpose of SMS are not being shared with third parties for marketing purposes.
Sharing of Your Information
We do not sell, trade, or rent your personal information to third parties. We may share your information with trusted third-party service providers who assist us in operating our website and services, provided they agree to keep this information confidential.
Security of Personal Data
Vespera will take reasonable precautions to protect Personal Data and Sensitive Data from loss, misuse, unauthorized access, disclosure, alteration, and destruction. For these purposes, Vespera will classify such data into three levels of security within Vespera:
a. Level 1 (known as “Vespera Public Data”)
This is Personal Data such as job title, workplace location, office telephone number and/or e-mail address. Vespera Public Data will be available for unrestricted use within Vespera and/or to Processors. Vespera Public Data may be disclosed outside of Vespera for General Business Purposes.
b. Level 2 (known as “Vespera Private Data”)
This is Personal Data such as the data subject’s home contact information, e.g., home address, home e-mail address, and home telephone number, as well as information about compensation and benefits, performance evaluations, and identification numbers. Vespera Private Data can only be disclosed for General Business Purposes to authorized personnel within Vespera and to Processors who are authorized to access and/or use such Vespera Private Data on behalf of a Vespera business unit. It will be disclosed to Third Parties only with the prior written permission of the concerned, except as may be allowed under appropriate law.
c. Level 3 (known as “Vespera Sensitive Data”)
Sensitive Data will be treated as highly-restricted data by Vespera and will be stored locally. Transfers of Vespera Sensitive Data, either outside the country of origin or outside of Vespera, will occur only as required for General Business Purposes. Recipients of Vespera Sensitive Data may include authorized Vespera Users or Processors who are authorized to access and/or use such Sensitive Data by a Controller authorized to have access to such Vespera Sensitive Data. Vespera Sensitive Data will be disclosed to Third Parties only with the prior written permission of the Data Subject, except as may be allowed under appropriate law.
Accountability
Vespera expects its employees, independent contractors, subcontractors, and partners to maintain the trust placed in Vespera by those Data Subjects who provide personal information to Vespera. Vespera will provide privacy training to its employees to highlight the importance of privacy in its global business. Those who manage personal information will complete periodic privacy self assessments to make sure that personal information is secure and protected. Vespera will periodically audit privacy compliance, and where necessary, will extend by contract its privacy policies and data protection practices to Vespera’s supplier and partner relationships.
Procedure for Accessing Personal Data
Vespera personnel must receive specific authorization in order to access Personal Data and Sensitive Data classified as Level 2 and above, except when a Data Subject requests access to his or her own data. Questions about Personal Data and/or authorization to access such Personal Data are to be directed to Data Subject’s Vespera management personnel. Unauthorized access may be grounds for disciplinary actions, including termination.
Transfer of Data
Subject to this policy, Vespera may from time to time transfer Personal Data and Sensitive Data within and between its various locations, if any, for General Business Purposes, in compliance with country of origin regulations and this Policy.
Vespera’s personnel, outside firms and consultants, and clients who receive Personal Data may be located in the Data Subject’s home country, the United States, or any other country in which Vespera or its affiliates do business. Therefore, Personal Data may be transferred to any country in the world, including but not limited to the United States of America, and where the privacy laws may be more or less protective than the privacy laws where the Data Subjects live or work.
Concerned individuals may withhold their consent to such international transfers, and are to be informed of the impact such opt-out will have on their employment within Vespera (e.g., inability to process benefits or payroll data in a timely or appropriate fashion).
Status of Policy
This policy is subject to change, although Vespera will provide updates from time to time about changes to this policy. In case of the sale of the company, acquisition or merger, bankruptcy or other change in corporate status, this Policy could change. In addition, this Policy may be supplemented by other company policies and statements.
For More Information
Questions or concerns about how Vespera manages Personal Data, are to be directed to the Data Subjects supervisor or appropriate Vespera management personnel. If you have questions about this privacy statement, or choose to opt out of any provisions hereof, please contact us at:
Vespera Assets LLC
43 South Pompano Parkway, PMB #112
Pompano Beach, FL 33069
USA
Telephone: (954) 580-0996
Facsimile: (954) 317-0530
Email: info@vesperalife.com
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