The information that we collect about you

We may collect and process the following information about you:

INFORMATION THAT YOU GIVE US

  • This is information about you that you give to us directly, for example, by completing a form or submitting an inquiry on one of our websites, giving us a business card (or similar), or corresponding with us by telephone, post, email, or otherwise. Information collected may include, for example, your name, address, email address and telephone number, information about your business relationship with VERBENA, and information about your professional role, background, and interests.
  • If you exchange emails, telephone conversations, or other electronic communications with our employees and other staff members, our information technology systems will record details of those conversations, sometimes including their content. Some of our premises have video surveillance systems that may record you if you visit our premises, for security and safety purposes.

INFORMATION WE COLLECT AUTOMATICALLY

  • When you visit one of our websites, it will automatically collect some information about you and your visit, including the Internet Protocol (IP) address used to connect your device to the Internet, your browser type and version, the pages on our website that you visit, and the referring URL. We collect this information passively by using technologies such as standard server logs, cookies, and clear GIFs (also known as “web beacons”).
  • One of the ways we collect information is through the use of cookies. A cookie is a small text file that may be placed on your device when you visit a website. Like many companies, VERBENA uses cookies to help you navigate our websites, and/or to save your preferences and settings when you return to the website. For more information about how VERBENA uses cookies, please see our Cookie Policy.

INFORMATION COLLECTED FROM OTHER SOURCES

  • We may also collect some information from other sources. For example, if we have a business relationship with the organization that you represent, your colleagues or other business contacts may give us information about you, such as your contact details or details of your role in the relationship. Also, we sometimes collect information from third-party data providers or publicly available sources for protecting our business and complying with our legal and regulatory obligations

HOW WE USE THE INFORMATION WE COLLECT

We may use your information for various purposes, including the following:

  • to operate, manage, develop and promote our business and, in particular, our relationship with you or the organization you represent, including by sending you communications regarding products or services that we think may be of interest to you. You may opt out of such communications at any time by following instructions included in each such communication;
  • to respond to an email, inquiry, or request sent by you, including for completing transactions with you or the organization you represent;
  • to operate, administer and improve our websites and premises and other aspects of how we conduct our operations;
  • to protect our business from fraud, money laundering, breach of confidence, theft of proprietary materials and other financial or business crimes; and
  • to comply with our legal and regulatory obligations, such as responding to a subpoena or a court order, and bring or defend legal claims.

From time to time, we may need to review information about you held in our systems – including the contents of and other information related to your emails and other communications with us – for compliance and business-protection purposes, as described above. This may include reviews for disclosure of information relevant to litigation and reviews of records relevant to internal or external regulatory or criminal investigations. To the extent permitted by applicable law, these reviews will be conducted reasonably and proportionately and approved at an appropriate level of management. They may ultimately involve the disclosure of your information to governmental agencies and litigation counterparties, as described below.

We will only process your personal information as needed to pursue the purposes described above, and then only where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes. In exceptional circumstances, we may also be required by law to disclose or otherwise process your personal information. We will tell you, when we ask you for compliance with a legal obligation or, on the other hand, if it is purely voluntary and there will be no implications if you decline to provide the information. Otherwise, you should assume that we need the information for our business or compliance purposes (as described above).

DISCLOSURE AND INTERNATIONAL TRANSFER OF YOUR INFORMATION

VERBENA is not in the business of selling personal information about our users to third parties. However, we may disclose information about you, including personal information, to other members of the VERBENA Group and/or for the purposes described above. These disclosures may involve transferring your personal information outside of the United States.  You should be aware that this may include transfers to countries outside the European Economic Area (“EEA”), which do not have similarly strict data privacy laws. In those cases, where we transfer personal data to other members of the VERBENA Group or our service providers, we will ensure that our arrangements with them are governed by data transfer agreements, designed to ensure that your personal information is protected, on terms approved for this purpose by the European Commission. Please contact us (see below) if you would like to know whether any such agreements are in place or to see a copy.

Our websites are hosted in the United States and are generally intended for United States visitors. If you visit one of our websites from outside the U.S., please be aware that you are transferring personal information to the United States and that the laws governing the collection and use of this information may differ from the laws in your region. By providing personal information to VERBENA, you are consenting to its use as described in this Privacy Statement.

NOTICE TO RESIDENTS OF THE EUROPEAN UNION

VERBENA’s websites are maintained for the purpose of selling and marketing products and services to organizations and individuals in the United States. Collection and storage of personal information related to any data subject in the European Union (“EU”) or European Economic Area (“EEA”) are minimal and incidental.

Notwithstanding the foregoing, if you are in the EU or the EEA, please be advised that VERBENA America LLC is the controller of your personal information. Our legal basis for collecting and using your personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.

You have the following rights:

  • to access, correct, update or request deletion of your personal information;
  • to object to the processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information;
  • If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

To exercise these rights contact us by email or at the address listed below under “Questions.”

GOOGLE ANALYTICS

Google Analytics collects information such as how often users visit our websites, what pages they visit when they do so, and what other sites they used prior to coming to our websites. We use this infor­mation to improve our websites. Google Analytics collects only the IP address assigned to you on the date you visit one of our websites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable infor­mation. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit our website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to our site is restricted by Google Analytics Terms of Use. To opt-out of being tracked by Google Analytics, visit the Google Analytics opt-out page.

YOUR CALIFORNIA PRIVACY RIGHTS

A business subject to California Civil Code section 1798.83 and/or California Consumer Privacy Act (CCPA) is required to disclose to its California customers, upon request, the identity of any third parties to whom the business has disclosed personal information within the previous calendar year, along with the types of personal information disclosed, for the third parties’ direct marketing purposes.

If you are a California resident and would like to make such a request, please submit your request in writing to us by email.

CALIFORNIA “DO NOT TRACK” DISCLOSURE

“Do Not Track” is a setting available in most web browsers setting that asks a web application to disable its tracking of an individual user. There is currently no consensus yet on how companies should respond to Do Not Track signals. At this time, we do not respond to Do Not Track signals.

LINKS

For your convenience, our website may contain links to other websites that we do not own or operate. Please be aware that this policy does not apply to any such third-party website. will not apply to your activities or any information you disclose while using third-party products or services or otherwise interacting with third parties.

RETENTION AND DELETION OF YOUR INFORMATION

We will retain your personal information for as long as it is needed for the purposes identified above and for any additional period required or permitted by law. You may request that we delete your personal information by contacting us via email at [email protected]. Unless we are required by law or have a legitimate interest to retain your information, we will delete it within 30 days of your request. Note, however, that we may retain some limited information about you even when we know that you have left the organization that you represent so that we can maintain a continuous relationship with you if we are in contact with you again when you represent a different organization.

YOUR RIGHTS

You may have a right to access the personal information that we hold about you, and to some related information, under data protection law. You can also require any inaccurate personal information to be corrected or deleted. You can object to our use of your personal information for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your personal information (and require them to be deleted) in some other circumstances.

CHANGES TO THIS STATEMENT

Any changes we make to this Privacy Statement in the future will be posted on this page. Please check back frequently to see any changes.

SECURITY

VERBENA uses reasonable security measures to protect against the loss, misuse, and/or alteration of personal information we control. Unfortunately, no security system, or system of transmitting data over the Internet, can be guaranteed to be 100% secure. As a result of the foregoing, while we strive to protect your personally identifiable information, we cannot guarantee the security of our servers, the means by which infor­mation is transmitted between your computer and VERBENA’s servers or any information provided to us or to any third party through or in connection with the Site. You provide all such information at your own risk.