VE3 (“we,” “us,” or “our”) offers digital business transformation services. This Privacy Notice sets out how we collect, use, share, and protect any information we collect through this website as well as in the context of external marketing events. This Privacy Notice also explains the measures we take to safeguard your information and describes how you may contact us regarding our privacy practices. 

Introduction: 

Any data collected through the Website or external marketing events held by VE3 or its partners, including personal data as defined under applicable data protection laws (collectively, “Personal Data”), will only be used for the purposes set out in this Privacy Notice. Notwithstanding, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. 

When data is collected on this Website, we are acting as a data controller. 

Please read this Privacy Notice thoroughly. If you disagree with the way Personal Data will be used, please do not use this Website or provide your Personal Data through the Website.

• Sources of Personal Data We Collect

We may collect the Personal Data outlined above from the following categories of sources: 

Information you provide directly.  For example, when you use the query form to inquire about our services, download a white paper, submit your information to us at an external marketing event or tradeshow, or to register for a Sapient-sponsored event. 

Information obtained from third parties.  Information about you that may come from data brokers, partners (e.g., those that offer co-branded services, sell or distribute our products, or engage in joint marketing activities), data analytics providers, and social networks. 

Information collected when you engage the Website. Information collected from you using automated technologies, such as cookies, pixels, third party tags, scripts, log files and other means to automatically collect information about the use of our Website. Further information about our use of cookies can be found in our Cookie Notice. 

Information from our Clients.  If Personal Data about you has been processed by us on behalf of a client (or any controller as per GDPR) and you wish to exercise any rights you have, we may have to ask you to inquire with our client directly. We will support the client (or controller) to the extent required by applicable law in responding to your request. 

Information we do not seek.  We do not intend to collect “special” or “sensitive” information from or about you (e.g., government identifiers, information on race or ethnicity, political opinions, religious beliefs, or health data).  We ask that you do not provide such information, and if we find such information, we will delete it.  

• Disclosures of Personal Data

The table below shows how and with whom we may share or disclose your Personal Data, and whether (based on the California Consumer Privacy Act’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months. 

We also may share any of the Personal Data we collect as follows:   

Sharing for Legal Purposes: In addition, we may share Personal Data with other parties in order to: (a) comply with legal process or a regulatory investigation (e.g. regulatory authorities’ investigation, subpoena, or court order); (b) enforce our Terms of Service, this Privacy Notice, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of other parties; and/or (d) protect the rights, property or personal safety of us, our platform, our customers, our agents and affiliates, its users and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, spam/malware prevention, and similar purposes. 

Sharing In the Event of a Corporate Transaction: We may also share Personal Data in the event of a major corporate transaction, including for example, a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all our assets, or for purposes of due diligence connected with any such transaction. 

Disaster Recovery: Amazon Web Services Ireland Ltd is providing the backup disaster recovery servers, which are in Ireland. If the services of third parties for the technical maintenance, administration or processing of data are required, the Personal Data will be accessed by these parties only to the extent that is required to ensure a smooth and secure technical handling of the Website and in compliance with applicable law, including with respect to data confidentiality, privacy and security. 

Aggregate, Deidentified, or Anonymized Information: We may aggregate, de-identify and/or anonymize any information collected so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any other party, including advertisers, promotional partners, and sponsors, in our discretion, unless otherwise prohibited by applicable law.

1. Exercising Your Rights and Choices

Please click here if you want to make use of any of your below mentioned legal rights.  If you wish to exercise your access rights, the service is provided by our vendor OneTrust as processor on our behalf. 

• Where You Are a Resident of the EU

1.1 General 

Subject to certain exceptions and the jurisdiction in which you live, if you are a resident of the EU, the General Data Protection Regulation (GDPR) provides you with specific rights regarding your Personal Data.  You may exercise the following legal rights regarding any Personal Data that we hold about you. 

Right of access:  You may access all Personal Data we hold about you, know the origin of this Personal Data, and obtain a copy in an understandable format; 

Right to rectification: You may request that we rectify inaccurate or incomplete Personal Data relating to you that we process or control; 

Right to erasure:  You may request the erasure or deletion of your Personal Data that we control.  We may be required to retain your Personal Data for legal or legitimate business reasons. 

Right to object to the processing of your Personal Data: You may at any time object to the processing of your Personal Data for reasons relating to your personal situation. We may nevertheless, on a case-by-case basis, reject such a request by pointing out the legitimate or otherwise legal reasons for processing this data. 

Right to restrict processing: You may request that our data processing related to you is limited, so that we may keep this data, but we cannot use it or process it in any other manner. This right applies in specific circumstances, i.e.: 

• if you challenge the exactness of your Personal Data, we may limit processing for a period of time so that the exactness of the Personal Data can be verified; 
• if you object to the erasure of your Personal Data and request instead that its use be limited; 
• if we do not need the Personal Data for the purposes mentioned above in Section III anymore, but you still need it to establish, exercise or defend rights before a Court; and 
• in the cases where you objected to the processing, which is based on the legitimate interests of the agency, you may ask to limit the processing for the time necessary for us to verify if we can accept your objection request (i.e., the time necessary to verify whether the legitimate reasons of the agency prevail over yours). 

Right to object to data processing for direct marketing purposes: You may unsubscribe to the object at any time and without any justification to the reception of direction marketing communications.  Simply either (i) click on the link in the footer of the communications you receive from us, (ii) use the link in this notice, or (iii) send us an email at the address in the “Further Information” section below with the word “unsubscribe” in the subject field of the email. 

Right to data portability: You have the right to receive the Personal Data provided by you, in a structured, commonly used and machine-readable format, for personal use or to share with a third party where our lawful basis for processing the Personal Data is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.  Please check the list of our Personal Data processing activities’ legal grounds (in Section III of this Privacy Notice) to know whether our processing is based on the performance of a contract or on consent. 

Right to withdraw your consent: You have a right to withdraw consent at any time where we process your Personal Data based on consent. 

If you are unsatisfied with the way we process your Personal Data or if your request has been rejected, you may also lodge a formal complaint with your local competent data protection authority. 

Subject to legal and other permissible considerations, we will act on your request promptly and in any event within one month from the date we receive your request. This timeframe can be extended by two months depending upon the complexity of the request or the number of requests received at a particular time. In this case, we will inform you within one month from receiving your request, specifying the reasons for extending the response timeframe. 

1.2 Data Transfers and Retention 

Due to the international nature of our business, your Personal Data may be transferred outside the European Union. Your Personal Data may be transferred to countries that are not considered to have the same level of data protection as in the EU. However, we ensure all data transfers comply with applicable legal requirements. 

Your Personal Data will be stored in accordance with our applicable data retention requirements and corporate policies. The retention period of your Personal Data varies depending on the type of Personal Data and the purposes of processing it. Your Personal Data will not be retained for any other purpose than that for which it was collected or for longer than is reasonably necessary for that disclosed purpose. 

1.3 Information from Our Clients 

If Personal Data about you has been processed by us as a processor on behalf of a client in the EU and you wish to exercise any rights you have with such Personal Data, please inquire with our client directly. If you wish to make your request directly to us, please provide the name of our client on whose behalf we processed your Personal Data. We will refer your request to that client and will support them to the extent required by applicable law in responding to your request.

2. Where You are a Resident of California

California residents, under the California Consumer Privacy Act of 2018 (“CCPA”), have specific rights with regard to their Personal Data. This section describes how to exercise those rights and our process for handling those requests.  (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.) 

Our website is intended to provide information and services to business clients. In such case, you understand and agree that information collected about you is solely within the context of (i) your role as an employee, owner, director, officer, or contractor or (ii) Publicis Sapient conducting due diligence regarding or providing or receiving a product or service to or from your employer. 

2.1 Information from Our Clients 

We also acknowledge that you may have rights under the CCPA in connection with the Personal Data we process on behalf of our clients. If Personal Data about you has been processed by us as a service provider on behalf of a client and you wish to exercise any of the rights described below, please provide the name of our client on whose behalf we processed your Personal Data. We will refer your request to that client and will support them to the extent required by applicable law in responding to your request. 

2.2 Rights to Request Access to Your Personal Data 

California residents have the right to request that we disclose what categories of Personal Data that we collect, use, disclose, or sell about them. In particular, California residents may request: 

• the specific pieces of Personal Data that we have collected about you; 
• the categories of Personal Data we have collected about you; 
• the categories of sources from which the Personal Data was collected; 
• the categories of Personal Data about you we disclosed for a business purpose or sold; 
• the categories of third parties to whom the Personal Data was disclosed for a business purpose or sold; and 
• the business or commercial purpose for collecting or selling the Personal Data.
  

2.3 Right to request deletion of your Personal Data 

You may also request that we delete any Personal Data that we have collected from you.  However, we may retain Personal Data for certain important purposes, as set out by law.  When we receive and verify your request to delete your Personal Data, we will proceed to delete the data unless an exception applies. 

2.4 Right to Non-discrimination 

We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these CCPA rights. 

2.5 Right to Opt-out of the sale of your Personal Data 

The CCPA broadly defines what constitutes a “sale” – including in the definition making available a wide variety of information in exchange for “valuable consideration.”  To the extent, we engage in the “sale” of your Personal Data as defined by CCPA, California residents may opt out of the “sale” of their Personal Data. 

Depending what information we have about you, and whether we have included any of it in our marketing products and services, we may have sold (as defined by California law) certain categories of information about you in the last 12 months, as described in the above table in Section IV of this Privacy Notice.  If you would like to opt out, you may do so by clicking Do Not Sell My Personal Information. 

2.6 Shine the Light 

Customers who are residents of California may request (i) a list of the categories of Personal Data disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in the “Further Information” section below and specify that you are making a “California Shine the Light Request.”