vagon is an online service that enables Cloud based computer usage and server space allocation through online systems via Applications (the “vagon Services”). This privacy statement is intended to provide information about how all Personal Information is collected, used, disclosed, processed and protected by vagon.
1. HOW WE COLLECT AND USE INFORMATION
We collect the following types of information about you:
1.1. Information you provide us directly: We may ask for certain information such as your username, first and last name, company name, phone number and e-mail address when you register for a vagon account, or if you correspond with us. We may also retain any messages you send through the vagon Services, and may collect information you provide in User Content you post to the vagon Services. We use this information to operate, maintain, and provide to you the features and functionality of the vagon Services.
1.2. User Content: We may also collect information regarding including but not limited to visual and auditory content, coding and data created or provided by the User that kept inside the Workstation (“User Content”). However, we do not have any access to your User Content and do not let any third parties have access to your User Content unless we are legally required to share your information as mentioned below in the Article 2.2. We may also access your User Content upon your explicit written consent.
1.3. Analytics information: We may directly collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the vagon Services. These tools collect information sent by your browser, including the pages you visit and other information that assists us in improving the vagon Services. We collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual user.
1.4. Cookies information: When you visit the vagon Services, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and lets vagon help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the vagon Services (e.g., the pages you view, the links you click and other actions you take on the vagon Services), and allow us or our business partners to track your usage of the vagon Services over time. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the vagon Services may not function properly if the ability to accept cookies is disabled.
1.5. Log file information: Log file information is automatically reported by your browser each time you access the vagon Services. When you use our vagon Services, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the vagon Services, domain names, landing pages, pages viewed, and other such information. Your log file information can be used as a legal evidence to prove whether your privacy rights on your User Content were violated.
1.6. Clear gifs/web beacons information: When you use the vagon Services, we may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the vagon Services.
1.7. Commercial and marketing communications: We use the information we collect or receive to communicate directly with you. We may send you emails containing newsletters, promotions and special offers. If you do not want to receive such email messages, you will be given the option to opt out or change your preferences. We also use your information to send you vagon Services-related emails (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the vagon Services, technical and security notices). You may not opt out of vagon Services-related e-mails.
DISCLAIMER: VAGON PROVIDES A CLOUD BASED SERVICE THROUGH WHICH YOU MAY ENTER INTO OR USE THIRD PARTY WEBSITES, SOFTWARE AND ETC. SERVICES. FOR EXAMPLE, IT IS POSSIBLE FOR YOU TO LOG INTO YOUR SOCIAL MEDIA ACCOUNTS, E-MAIL ACCOUNTS AND EVEN BANK ACCOUNTS OVER THE VAGON SERVICES. PLEASE NOTE THAT VAGON HAS NO CONTROL OVER, NOR ANY LIABILITY WHATSOEVER FOR ANY PERSONAL DATA THAT YOU PROVIDE TO THIRD PARTIES WHILE USING VAGON SERVICES. PLEASE REFER TO THE PRIVACY POLICIES OF THE THIRD PARTIES ENGAGED THROUGH VAGON SERVICES FOR MORE INFORMATION.
2. PURPOSE OF COLLECTION AND PROCESSING
As stated in more detail in our Terms of Service, vagon does not use any identifiable processed data for purposes not stipulated in any legal document of vagon. In order for a personal data to be processed, it is only necessary for vagon to serve to the relevant person. Below is a set of descriptions of the methods through which we plan to use your personal data. vagon is an online service that enables Cloud based computer usage and facilitates a server space. We can provide you an area which can be used for your business. In addition to this, vagon does not access to your own data that you assign in the space allocated to you. We also ensure that nobody will access to your files through the logging system that we use. Our system can detect in cases of unauthorized logging attempt to your account. The purpose of collection and processing is to:
- administer our courses or events
- to improve and develop our Platform and conduct product development
- communicate with you
- to help us collect information of abuse, fraud, and illegal activity on vagon Services
- to enforce our terms, conditions, and policies
- manage, administer and promote opportunities
- comply with a legal or regulatory obligations.
- manage our websites and social media accounts
Please do not forget to consider that your personal data may be processed for more than one lawful ground depending on the specific purpose for which they are being used. If you need answers about the specific legal grounds, please do not hesitate to send an email to us via email@example.com
3. SHARING YOUR INFORMATION
We will not rent or sell your information to third parties outside vagon and its group companies (including any parent, subsidiaries and affiliates) without your consent, except as noted below:
3.2. Instances where we are required to share your information: vagon will disclose your information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to
(a) comply with the law and the reasonable requests of law enforcement;
(b) to enforce our vagon Terms of Service or to protect the security or integrity of our vagon Services; and/or
(c) to exercise or protect the rights, property, or personal safety of vagon, our Users or others.
3.3. Sharing certain service type information we collect about you: We may share certain service type information, including information obtained through tools such as cookies, log files, and clear gifs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.):
(i) with our third-party business partners for the purposes described in the section above on “Purpose of Collection and Processing”. We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties
4. HOW WE STORE AND PROTECT YOUR INFORMATION
4.3. Compromise of information: In the event that any information under our control is compromised as a result of a breach of security, vagon will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
5. YOUR RIGHTS AND PREFERENCES ABOUT YOUR INFORMATION
You may have heard about the General Data Protection Regulation (“GDPR”) in European Union.
You may have heard of the law that adopted this regulation in 2016 which aims to secure your personal data. The law called “GDPR” gives you certain rights regarding your personal data. vagon recognizes and will comply with GDPR and the rights associated with the GDPR, except as limited by the applicable law. You have the following rights:
5.1. Request access regarding your personal data. You are entitled to receive an explanation about the processing, storage, sharing, storage, security of your personal data. You may obtain information concerning how your personal data is processed.
5.2. Request correction of the personal data that we keep. You are entitled to request correction of your personal information that are incomplete or inaccurate.
5.3. Request erasure of your personal data. You are entitled to request the deletion or removal of your personal data when there is no good reason for us to continue processing it (also known as the “Right to be forgotten”). This right allows you to request the deletion of your personal data in certain limitations under the applicable law.
5.4. Right to Complain. You have the right to make a complaint at any time to the appropriate supervisory authority for data protection issues. Hence we kindly request that you contact us first and give us the chance to deal with your concerns before you apply to the supervisory authority. We will endeavor to deal with your request as soon as possible.
5.5. Request restriction of processing of your personal data. You are entitled to request restriction or suspension on the use or process of your personal information.
5.6. Right to Object. You are entitled to object the process and use of your personal data in certain circumstances. However, vagon reserves the right to not comply with such requests in case (i) vagon has compelling legitimate grounds for processing the personal data which override the interests, rights and freedoms of the data owner, or (ii) it is necessary for the establishment, exercise or defense of legal claims.
5.7. Request the transfer of your personal data to you or to a third party. You are entitled to receive the personal information we have about you and to transfer it to any third party.
5.8. Right to not become subject of Automated Decision-Making. You are entitled to object and prevent decision and execution that could have a legal, in all probability that effect on you from being made solely based on automated processes. You are entitled to request not to be subject to a decision solely based on automated processing, including profiling which may produce legal effects about you or similarly significantly affects you. However, vagon reserves the right to disregard such request in case (i) it is necessary for entering into, or performance of, a contract between the data owner and a data controller, or (ii) vagon is authorized by the relevant country to which the Data Controller is subject to and which lays down suitable measures to safeguard the data owner’s rights and freedoms and legitimate interests; or (iii) is based on the data owner’s explicit consent.
You have the right to withdraw your consent about your processed data. However, this will not affect the lawfulness of any processing carried out before your withdrawal. If you withdraw your consent, we may not be able to provide certain products or services which require the collection, use, process of and other activities related to the Personal Data. Many of these rights can be exercised by signing in into the system and directly updating your account information. These rights can only be implemented if you use the Services and your personal data is processed. Please be aware that some of these rights may be unusable in certain circumstances as stipulated in GDPR or any applicable law. If you have questions or concerns about statements, policy or rights herein please do not hesitate to contact us at firstname.lastname@example.org
You also have certain preference options while using vagon Services. These are:
A. Control your account information and settings: You may update your account information and email-communication preferences at any time by logging into your account and changing your profile settings. You can also stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. As noted above, you may not opt out of vagon Services-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the vagon Services, technical and security notices). If you have any questions about reviewing or modifying your account information, you can contact us directly at email@example.com.
B. Opting out of collection of your information for Tracking: Please refer to your browser’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Note that disabling cookies and/or other tracking tools prevents vagon or its business partners from tracking your browser’s activities in relation to the vagon Services. However, doing so may disable many of the features available through the vagon Services. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at firstname.lastname@example.org.
6. PERSONAL DATA IN EU
The purpose of this section is to inform you about how your Personal Data are processed in and transferred in and out of EU.
7. SECURITY OF THE SERVICES
7.1 vagon will take technical and organizational security measures to keep user data safe. Security measures are aimed for (i) the protection of the user data, against any unauthorized access and (ii) to ensure that the Services function properly. However, in addition, the User shall take the necessary measures to ensure ultimate security of their workstations and user contents. In this context, the User accepts (i) that vagon cannot be responsible from all security breaches and (ii) that the User is responsible for all errors and their direct or indirect con-sequences that may occur in his / her software and operating systems upon visiting or using vagon’s Services.
7.2. vagon reserves the right to access the user data in the following cases. In these cases, Users will be notified of any access by vagon.
A. (i) As required by the law that will be applied to the Agreement or (ii) that the User is subject to or (iii) as requested by a court order.
B. To comply with the decision of a State body which the User or the Company is obliged to comply with,
C. Violation of the Agreement which may damage vagon.
7.3. Users shall take necessary measures to protect User Content and protect their vagon Services workstation against unauthorized access. Users shall notify the vagon immediately, in case of an unauthorized access to their Workstation or sufficiently suspected on a breach of the security and privacy of Users Content.
8. CHILDREN’S PRIVACY
vagon does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register as Users. vagon Services and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at email@example.com.
9. OUR COOKIES POLICY
We use both session and persistent cookies on the Service. We may use essential Cookies to authenticate users and prevent fraudulent use of user accounts.
9.3. In addition to our own Cookies, we may also use various third-parties Cookies to report usage statistics of the Service, deliver advertisements on and through the vagon Services, and so on.
10. LINKS TO OTHER WEBSITES AND SERVICES
11. STORAGE AND DELETION OF DATA
We keep your information as long as we serve you. Thus, we also respect your rights and obligations in the contract. When you cancel your account, all personal data processed or collected will be purged within commercially reasonable time. Where we do not need any information to provide the Services, we will retain it only for 30 days however, if we have a legitimate business purposes for keeping such data related to the provision of Services , we will retain it until such necessity ceases.
12. INFRINGEMENT OF IP RIGHTS OF THIRD PARTIES
vagon shall not be held liable for infringement of any copyrighted work uploaded on or created at Users’ Workstations. vagon does not have any access or authority on User Content. If third parties believe their IP rights are infringed by vagon Users they should contact them directly and assert their DMCA rights directly.
13. CONTACT US