PRIVACY SHIELD FRAMEWORK NOTICE - VIMANA ELEVATE

Effective as of May 25, 2018

VIMANA (“VIMANA” or “We” or “Our”) has certified VIMANA Elevate, our cloud-based analytics platform, for which we act as a data processor  under both the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework (collectively, “Privacy Shield”). VIMANA certifies  that it adheres to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement for personal  data submitted by our customers in participating European countries through VIMANA Elevate. If there is any conflict between the terms in this  Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. For more information on the Privacy Shields, visit the U.S.  Department of Commerce’s Privacy Shield website at https://www.privacyshield.gov/.

We commit to periodically review and verify the accuracy of our policies and our compliance with the Privacy Shields. If there is any conflict  between the Privacy Shield and our policies (including this Framework Statement), the principles of the Privacy Shield shall govern where  applicable. 

Our Privacy Shield certifications can be found here.

SCOPE

VIMANA’s participation in the Privacy Shield applies to VIMANA Elevate. VIMANA Elevate provides predictive analytics for discrete manufacturing . VIMANA Elevate is a B2B service delivered to our customers, where our customers are the Controller and VIMANA is the Processor.

DATA PROCESSED

We collect the following types of personal data:

  • contact information, such as: email, phone number, sms address
  • operator machine usage, such as: operator ID, operator machine login/logout times (if optionally configured)
  • external Login ID (if optionally using an external authentication service)

We also collect data for security and monitoring, such as:

  • log and usage data

PURPOSE OF DATA PROCESSING

We process personal data submitted directly from users and collected from factory devices for the purpose of providing VIMANA Elevate to  customers. To fulfill these purposes, we may access data to prevent or address service or technical problems, to respond to customer support  matters, to follow the instructions of our customer who submitted the data, or in response to contractual requirements with our customers.

CHOICE

If Personal Data covered by this Privacy Shield Statement is to be used for a new purpose that is materially different from that for which the  Personal Data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party, Vimana will provide Data  Subjects with an opportunity to choose whether to have their Personal Data so used or disclosed. 

If Sensitive Personal Data covered by this Privacy Shield Statement is to be used for a new purpose that is different from that for which the  Personal Data was originally collected or subsequently authorized, or is to be disclosed to a third party, Vimana will obtain the Data Subject’s  consent prior to such use or disclosure.

ACCOUNTABILITY FOR ONWARD TRANSFERS

Personal data may be shared with sub-processors used to deliver VIMANA Elevate. VIMANA maintains contracts with these sub-processors  restricting their access, use, and disclosure of personal data in compliance with our Privacy Shield obligations, and VIMANA may be liable if they  fail to meet those obligations and we are responsible for the event giving rise to damage.

ACCESS

Some international users (including those whose personal data is within the scope of this Privacy Shield certification) have certain legal rights to  access personal data we hold about them and to obtain its correction, amendment, or deletion. In most cases the user can correct, amend, or  delete their personal data directly via VIMANA Elevate. When this is not possible you can submit a request to dpo@govimana.com.

SECURITY

VIMANA takes reasonable and appropriate precautions, taking into account the risks involved in the processing and the nature of the personal  data, to help protect personal data from loss, misuse and unauthorized access, disclosure, alteration, and destruction.

INQUIRIES AND COMPLAINTS

If you have any questions, concerns, or complaints regarding our privacy practices, or if you’d like to exercise your choices or rights, you may  direct your inquires to dpo@govimana.com. We will respond to your inquiry within 45 days of receipt and verification of your identity.

Within the scope of this privacy notice, if a privacy complaint or dispute cannot be resolved through VIMANA’s internal processes, VIMANA has  agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure. Subject to the terms of the VeraSafe Privacy Shield Dispute  Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe under the Privacy  Shield Dispute Resolution Procedure, please submit the required information to VeraSafe here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/

If neither we or VeraSafe are able to resolve your complaint, as a last resort you may engage in binding arbitration through the Privacy Shield Arbitration Panel, described at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

ENFORCEMENT AND COMPELLED DISCLOSURE

Our commitments under the Privacy Shield is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. We  may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law  enforcement requirements. Under such circumstances, we may be prohibited by law, court order, or other legal process from providing notice of  disclosure.

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