PRIVACY STATEMENT...

rev. September 28, 2016

VAMCORP Holdings Ltd.* and its affiliates (“VAMCORP”) are concerned about privacy issues and want you to be familiar with how we collect, use and disclose information.  Together with VAMCORP’s  Privacy Policy, this Privacy Statement describes VAMCORP practices in connection with information that we collect through the website or mobile application owned and controlled by VAMCORP from which you are accessing this Privacy Statement (respectively, the “Site” and the “App”), as well as offline where notice is legally required. By providing Personal Information to VAMCORP, you agree to the terms and conditions of this Privacy Statement. 
If you apply for a job through the Site, VAMCORP use of the Personal Information you provide through the Career Center is governed by a separate privacy notice, not this Privacy Statement.

PERSONAL INFORMATION

Personal Information VAMCORP Collects

“Personal Information” is information that identifies you as an individual, such as:

• Name;
• Postal address (including billing and shipping addresses);
• Telephone or fax number;
• Email address;
• Credit and debit card number;
• Vendor Tax ID numbers;
• Financial information when you apply for credit;
• Purchase history.

VAMCORP collects Personal Information when you participate in various opportunities that we provide, for example:

• When you order a product or service or make a request.
• When you register your purchase of a VAMCORP product.
• When you submit a warranty card.
• When you register for subscriptions, technology forum or other communications through the Site or App.
• When you participate in a contest, promotion, sweepstakes, survey or other promotion.
• When you participate in a blog or forum.
• When we conduct market research, meet you at a trade show or another event.

We may combine Personal Information that we collect about you with Personal Information you provide to VAMCORP through other sources, such as product registrations, inquiries or marketing events. We will use the combined Personal Information in accordance with this Privacy Statement for as long as it is combined.

How We Use Personal Information

We may use Personal Information for the following purposes:

• Respond to your inquiries and fulfill your requests, such as to send you e-mail alerts.
• Send you important information regarding the Site or App, changes to VAMCORP’s terms, conditions, and policies and/or other administrative information. 
• Complete and fulfill your purchase, for example, to process your payments, have your order delivered to you, communicate with you regarding your purchase and provide you with related customer service.
• Send you marketing communications that we believe may be of interest to you, including information about trade shows.
• Personalize your experience on the Site by presenting products and offers tailored to you.
• Allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information, so we suggest that read these rules carefully.
• Permit you to send messages to a friend through the Site or App. By using this functionality, you are telling VAMCORP that you are entitled to use and provide VAMCORP with your friend’s name and email address. 
• Allow you to communicate and interact with others through the Site or App (for example, through a blog, message board, messaging functionality, chat functionality, profile or another social media).
• Permit you to register and participate in technology forums and other events with VAMCORP.
• Enable VAMCORP business purposes, such as data analysis, audits, researching and developing new products, enhancing VAMCORP’s website, improving VAMCORP’s services, developing marketing events, identifying usage trends and determining the effectiveness of VAMCORP’s promotional campaigns. 
• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce VAMCORP terms and conditions; (e) to protect VAMCORP operations; (f) to protect VAMCORP rights, privacy, safety or property, you or others; and (g) to allow VAMCORP to pursue available remedies or limit the damages that we may sustain.

How Personal Information is Disclosed

• Your Personal Information may be disclosed:
• Within the VAMCORP Group of Companies for the purposes described in this Privacy Statement. VAMCORP Holdings Ltd. and the local affiliate with whom you are interacting are jointly responsible for the management of the jointly-used Personal Information.
• To VAMCORP’s third party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, product distribution, infrastructure provision, IT services, customer service, email delivery services, credit card processing, auditing services and other similar services to enable them to provide services.
• To third parties such as agents and distributers to facilitate the sale and distribution of VAMCORP products and services which may include marketing communications.
• To third parties sponsors of sweepstakes, contests and similar promotions.
• To identify you to anyone to whom you send messages through the Site.
• To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of VAMCORP business, assets or stock (including in connection with any bankruptcy or similar proceedings).
• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce VAMCORP terms and conditions; (e) to protect VAMCORP operations; (f) to protect VAMCORP rights, privacy, safety or property, you or others; and (g) to allow VAMCORP to pursue available remedies or limit the damages that we may sustain.
• By you, when you participate in features on a VAMCORP Site or App that provide the opportunity to interact with VAMCORP and others (for example a blog, message board, messaging functionality, chat functionality, profile or other social media).  When you use these features you should be aware that any information you submit, including your name, location and e-mail address, may be publicly available to others. We are not responsible for any information you choose to submit through these features and we strongly discourage you from disclosing any sensitive Personal Information (such as health or credit card information) through these features.  If you use these features, your Personal Information may remain on the Site or App even after you cease use of the Site or App.

NON-PERSONAL INFORMATION

Non-Personal Information We Collect

“Non-Personal Information” is any information that does not reveal your specific identity, such as:

• Browser information;
• Information collected through cookies, pixel tags and other technologies;
• Demographic information and other information provided by you;
• Aggregated information.

How We Collect Non-Personal Information

VAMCORP and VAMCORP’s third party service providers may collect Non-Personal Information in a variety of ways, including:

• Through your browser:  Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version and Internet browser type and version.
• Using cookies:  Cookies allow a web server to transfer data to a computer for recordkeeping and other purposes.  We use cookies and other technologies to, among other things, better serve you with more tailored information, to facilitate your ongoing access to and use of the Site, and to provide you with personalized marketing.  If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies.  Some features of the Site may not work properly if you decline the use of cookies.  To learn more about cookies, please visit http://www.allaboutcookies.org/
• Using pixel tags, web beacons, clear GIFs or other similar technologies:  These may be used in connection with some Site pages and HTML-formatted email messages to, among other things, track the actions of Site users and email recipients, measure the success of VAMCORP marketing campaigns and compile statistics about Site usage and response rates. 
• From you:  Information such as your location, as well as other information, such as your preferred means of communication, is collected when you voluntarily provide this information.  Unless combined with Personal Information, this information does not personally identify you or any other user of the Site or App.
• By aggregating information:  Aggregated Personal Information does not personally identify you or any other user of the Site or App, (for example, we may use Personal Information to calculate the percentage of VAMCORP users who have a particular telephone area code).

How We Use and Disclose Non-Personal Information

Because Non-Personal Information does not personally identify you, we may use and disclose Non-Personal Information for any purpose.  In some instances, we may combine Non-Personal Information with Personal Information (such as combining your name with your geographical location).
If we combine any Non-Personal Information with Personal Information, e.g., when we combine information you provide upon registration with Non-Personal Information to provide you with targeted personalized marketing, the combined information will be treated by VAMCORP as Personal Information. 

IP ADDRESSES

Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP).

How We Collect IP Addresses

An IP Address is identified and logged automatically in VAMCORP server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited.  Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites.

How VAMCORP Uses and Discloses IP Addresses?

VAMCORP uses IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, administering the Site and presenting content that is tailored to your country.  We may also use and disclose IP Addresses for all the purposes for which we use and disclose Personal Information.  Please note that we treat IP Addresses, server log files and related information as Non-Personal Information, except where we are required to do otherwise under applicable law.

INTEREST-BASED ADVERTISING

VAMCORP and VAMCORP third party service providers use cookies, pixel tags, web beacons, clear GIFs or similar technologies to track the actions of Site users and email recipients across non-affiliate websites over time, in order to personalize your experience on the Site by presenting advertisements that are more relevant to you.  For example, we use third party service providers, to present products and offers tailored to the preferences and interests demonstrated by your online activity over time.

THIRD PARTY SITES

This Privacy Statement does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which the Site or the App contains a link.  The inclusion of a link on the Site or the App does not imply endorsement of the linked site by VAMCORP.

THIRD PARTY ADVERTISERS

VAMCORP may use third-party advertising companies to serve ads when you visit a VAMCORP Site.  Please note that these companies may use information about your visit to this Site in order to provide advertisements about goods and services that may be of interest to you.  In the course of serving advertisements to this Site, these companies may place or recognize a unique cookie on your browser.  If you would like more information about this practice and to know your choices about not having this information used by these companies, please visit http://networkadvertising.org/optout_nonppii.asp.

SECURITY

VAMCORP uses reasonable organizational, technical and administrative measures to protect Personal Information under VAMCORP control.  Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with VAMCORP is no longer secure (for example, if you feel that the security of any account you might have with VAMCORP has been compromised), please immediately notify VAMCORP of the problem by contacting VAMCORP in accordance with the “Contacting VAMCORP” section below.

CHOICES AND ACCESS

Your choices regarding VAMCORP’s use and disclosure of your Personal Information

VAMCORP gives you many choices regarding VAMCORP’s use and disclosure of your Personal Information for marketing purposes.  By contacting VAMCORP, you may opt-out from receiving future electronic marketing messages from VAMCORP and request that we not share your Personal information with unaffiliated third parties for their marketing purposes.
We will try to comply with your request(s) as soon as reasonably practicable.  Please note that if you opt-out as described above, we will not be able to remove your Personal Information from the databases of unaffiliated third parties with which VAMCORP has already shared your Personal Information (i.e., to which we have already provided your Personal Information as of the date that we implement your opt-out request).  Please also note that if you do opt-out of receiving marketing-related messages from VAMCORP, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.

How you can access, change or suppress your Personal Information

If you would like to review, correct, update, suppress, delete or otherwise limit VAMCORP use of your Personal Information that has been previously provided to VAMCORP, you may contact VAMCORP.
In your request, please make clear what information you would like to have changed, whether you would like to have your Personal Information suppressed from a VAMCORP database or otherwise let VAMCORP know what limitations you would like to put on VAMCORP use of your Personal Information.  We will try to comply with your request as soon as reasonably practicable.

RETENTION PERIOD

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or allowed by law.

USE OF SITE BY CHILDREN

VAMCORP is committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children’s online activities.  VAMCORP does not target the Site or the App to children less than fourteen (14) years of age or knowingly collect information from children for the purpose of selling products or services. VAMCORP does participate in select educational programs such as science and environmental awareness in support of schools and communities.

CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or where we have engaged a service provider, and by using VAMCORP Site or App you consent to the transfer of information to countries outside of your country of residence, including to the United States, which may have different data protection rules than in your country.

SENSITIVE INFORMATION

We ask that you not send VAMCORP, and you not disclose, any sensitive Personal Information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Site or App or otherwise to VAMCORP.

UPDATES TO THIS PRIVACY STATEMENT

We may change this Privacy Statement.  Please take a look at the “LAST UPDATED” legend at the top of this page to see when this Privacy Statement was last revised.  Any changes to this Privacy Statement will become effective when we post the revised Privacy Statement on the Site or App.  Your use of the Site or App following these changes means that you accept the revised Privacy Statement.

CONTACTING VAMCORP

If you have any questions about this Privacy Statement, please contact VAMCORP at VAMCORP.