Versal Group, Inc. (“Versal”, “we”, “us” or ”our”) provides a publishing platform for creating, managing, sharing and publishing interactive, online courses (“Courses”). Versal understands the importance of privacy and data protection. In this Privacy Policy (the “Policy”) we describe how Versal handles the information we collect about visitors to our website(s), including www.versal.com and other sites on which we post this Policy (the “Sites”), from users of our platform and services (the “Services”), about customers and prospective customers, and from others who communicate with us about the Sites and Services.
In this Policy, personal data means information relating to an identified or identifiable individual. In contrast, anonymous data means data that is not associated with, does not directly or indirectly identify, and could not be used to identify a particular individual (or combined with other information to do so). We collect and use personal data and anonymous data, as described in this Policy.
means individuals as well as that are institutions, enterprises or other organizations and their authorized users and administrators, who have registered for a paid or a free (including trial) account with Versal
are the Learners, Contributors and others who access or are invited to access a Customer’s Courses.
Courses and all content that is collected, created, submitted, or uploaded to Courses by Customers and their End Users (collectively, the “Course Content”), as well as any personal data that is submitted or collected by Customers or from or their End Users (the “End User Information”) is owned by the respective Customers. Customers may submit, upload, collect or manage End User Information through the Services, such as email addresses, attendance and participant lists. course progress and activity, and quiz and assessment results. Customers are responsible for ensuring that their collection, use and disclosure of Customer Content and End User Information complies with applicable laws.
Versal is a data processor under of the Customer Content and End User Information (including any personal data), under General Data Protection Regulation (GDPR). We will only collect, use and disclose Customer Content and End User Information (including any personal data) under the instructions of our Customers, in order to provide the Services to them, or where otherwise required by law. If you have a request or inquiry related to your personal data that we hold as a data processor, you should contact the relevant Customer. If you have any questions, or are unable to reach the relevant Customer, you may contact us using the contact details below, and we will attempt to forward your request to the relevant Customer.
We collect information directly from individuals, automatically through the use of our Services and Sites, and also from third parties.
We collect account-related information about Customers when they register with us, make payments, access the Services, contact us, or request customer service or support, as well as usage information and log files about their access to and use of the Services (“Account Information”). Account Information – which does not include the Customer Content or End User Information – includes:
When Customers create an account on our website, we collect their name and email address, company or institution, as well as a password. We may also collect additional information as part of Customer profiles, such as a biography provided by you. If you provide a display name, profile image, biography, or location in your Customer profile, this information will be visible to others, including anonymous visitors to the Site. Providing this information is optional, and you may update or delete it at any time. If you use the Services through an organization, they may provide us with information about you so that we can grant you access to the Services.
We collect information, such as name, billing address, and other credit card or payment details, to bill you for our Services; we also maintain records of your membership and payment history with Versal.
When you email us, call us or contact us, we maintain records about our interactions and communications with you. We also maintain records related to customer support and customer service-related requests we respond to or receive.
When you post messages on our message boards, the information contained in your posting will be stored on our servers and other users and visitors to the Site will be able to see it. You may remove or ask us to remove your contributions to the message board at any time.
When you participate in a survey distributed by Versal, we may collect additional information from you, such as background and demographics as relevant to the survey. Your participation in surveys is optional.
Unpublished Course Content is visible only to you and other authorized course administrators of your account or organizational account. Once published, Course Content is either public or private. When Customers post content under an Organization account, the Course Content is private by default and can be made public. For Customers that post Customer Content under a Versal Free or Pro account, the default setting is public, which may be changed to private before the Customer Content is published. Customer Content published under a Free account is public, but may be changed to private once the account is converted to a paid account. Customer Content may also be deleted as set forth in the “Your Choices” section below.
When Customers post Customer Content publicly through the Versal Services, the Customer Content will be viewable by anyone visiting the Site, along with your name and any other information that is set to public on your profile page (“Profile”). Customer Content published and shared publicly may be accessed by others and indexed by search engines.
The content you set to private is visible to you and to your invited learners and contributors, and is not indexed by search engines. If your course is part of an Organization account, it is visible to others in the same organization. The title and description of your Course Content may be viewable by others, but not the content itself.
We use cookies, log files, pixel tags, local storage objects, and other tracking technologies to automatically collect information when users access or use the Services or visit our Site, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider (“ISP”), referring/exit URLs, operating system, language, clickstream data, and other information about the links clicked, features used, size of files uploaded, streamed or deleted, and similar device and usage information. For more information on how to manage your preferences, see the Cookies and Tracking section below.
As you will see, you may use third party gadgets to add content to your Courses through the Versal Services. Examples of Third-Party Gadgets include Google Docs, Microsoft OneDrive, Quizlet, Sketchfab, and Prezi. Those gadgets may collect information from you. We do not control third-party gadgets and we are not responsible or liable for the information or use of information collected through these gadgets. You should consult their respective privacy policies for information about their practices.
We do not sell your personal data – such as your name and contact information – to third parties to use for their own marketing purposes. We only collect information for the following legitimate purposes:
to create your account, validate that you are an authorized user, secure your account and Customer Content, to prevent unauthorized access, for defect and error reporting and resolution, to perform upgrades and maintenance, and for other similar purposes.
to provide and operate our Services and the Sites, communicate with you about your use of the Services, respond to your inquiries, provide troubleshooting, fulfill your orders and requests, process your payments, and complaints and inquiries, provide technical support, and for other customer service and support purposes.
to tailor content we send or display to you in order to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.
for direct marketing and promotional purposes. For example, we may send you newsletters, special offers or promotions, and contact you about Versal products or information we think may interest you. If you are located in a jurisdiction that requires opt-in consent to receive electronic marketing messages, we will only send you such messages if you opt-in to receive them. As explained above, we do not use Customer Content for direct marketing purposes.
To better understand how users access and use the Sites and Services, and for other research and analytical purposes, such as to evaluate and improve the Services and to develop additional products, services and features. While we may collect and analyze usage data (e.g., storage size used, access logs, etc. and content metadata such as gadget types, tags, learner count, number of lessons etc.) related to Customer Content, we do not access or read individual course content for these purposes.
To protect the Services, prevent unauthorized access and other misuse, and where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Use or this Privacy Policy.
To comply with the law or legal proceedings; for example, we may disclose information in response to lawful requests by public authorities, including responding to national security or law enforcement disclosure requirements.
Where necessary to the administration of our general business, accounting, recordkeeping and legal functions.
our processing (i.e. use) of your personal data (as a data controller) is justified on the following legal bases:
| Purpose of Processing (see above) | Legal Bases of Processing (EU Users)* |
Account Management and Maintenance Providing Support and Services | Our Legitimate Business Interests** Where Necessary to Perform a Contract with You (upon your request, or as necessary to make the Services available) Where Necessary to Establish, Exercise or Defend Legal Claims and Rights Compliance with Law |
Personalization Marketing and Promotions | Our Legitimate Business Interests** With Your Consent |
Analytics and Improvement | Our Legitimate Business Interests** With Your Consent |
Protect Our Legal Rights and Prevent Misuse Comply with Legal Obligations | Our Legitimate Business Interests** Compliance with Law Where Necessary to Establish, Exercise or Defend Legal Claims and Rights |
General Business Operations | Our Legitimate Business Interests** Where Necessary to Establish, Exercise or Defend Legal Claims and Rights |
*For the personal data from the EU that we process, this column describes the relevant legal bases for such processing under GDPR (and local implementing laws of EU member states); this does not limit or modify the obligations, rights and requirements under the privacy laws of non-EU jurisdictions.
** For the personal data from the EU, the processing is in our legitimate interests, which are not overridden by your interests and fundamental rights. Marketing to the EU only with opt-in consent.
As noted above, we are a data processor with respect to Customer Content and End User Information, and our Customers are responsible for how this data is collected, used and disclosed.
Customer Content that is set to public, as well as the relevant Customer’s name and public profile information may be viewed publicly, by registered and non-registered users, and we can’t prevent such users from sharing such content. In addition, Customer Content that is public may be indexed by search engines. See the section below about “Your Choices” for information about how you may change how certain information is shared or viewed by others.
If you use the Services under an Organization account, Customer Content, End User Information, and other information associated with your account may be disclosed to the enterprise or an administrator on the enterprise account.
Some of the Versal Services may enable you to post content to social networking sites (e.g., Facebook or Twitter). If you choose to do this, we will provide information to such social networking sites in accordance with your elections.
We may share your information with third party service providers who use this information to perform services for us, such as payment processors, hosting providers, auditors, advisors, consultants, and customer service and support providers.
The information collected about you may be accessed by or shared with our subsidiaries and affiliates, whose use and disclosure of your personal data is subject to this Privacy Policy.
We may disclose or transfer information, including personal data, as part of any merger, sale, and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event.
We may disclose your information if we are required to do so by law (e.g., to law enforcement, courts or others, e.g., in response to a subpoena or court order).
We may disclose information where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and protect the rights, property or safety of Versal, its users, or others.
We may share aggregate or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.
We often receive testimonials and comments from users who have had positive experiences with the Versal Services. We occasionally publish such content, with the User’s consent. When we publish this content, we may identify our users by their first and last name and may also indicate their home city. We obtain the user’s consent prior to posting his or her name along with the testimonial. You may request that we remove your testimonials by contacting us as set out below.
We may set cookies for your web browser as you visit our website or use our products. A cookie is a small data file that is stored on a computer for the purpose of identifying that browser during interaction on websites. Cookies may be delivered by the web page, via a visible image or content frame on a page, or using small strings of invisible code placed into the web page for this purpose, and known as web beacons, clear GIFs, or pixel tags. A website may set a cookie to the browser if the browser's preferences allow it. We may use cookies for a number of purposes, including to access your information when you sign in so we can provide you with customized content, keep track of preferences or remember the last page you visited in a product or service. Also, when you log in to your account, a cookie associated with your account is placed on the computer or device you are using. This allows us to display your account preferences and status if you log in to your account on multiple devices, so they are displayed in the same manner on any device. For more details on how to manage your preferences please see our Cookies Policy.
We may use internal and third party analytics tools, including Google Analytics.The third party analytics companies we work with may combine the information collected with other information they have independently collected from other websites and/or other online products and services. Their collection and use of information is subject to their own privacy policies.
Please note we do not change system behavior within the Sites and Services in response to browser requests not to be tracked. You may, however, disable certain tracking by disabling cookies; see our Cookies Policy for more detail.
The website is not directed to individuals under the age of 16, and we request that such individuals do not use or provide personal data through the website. If we discover that we have collected any personal data of children under the age of 16, we will immediately delete it. If you are under 16, or believe your children under the age of 16 have registered with our service, please notify us immediately at help@versal.com.
Our Customers are responsible for determining how to manage Customer Content and End User Information, and any associate personal data, as well as how to respond to individual’s request related to such personal data. Please keep in mind, if you are not the Admin of an Organization account, you may need to contact the Organization, to delete your Courses, and any Customer Content or End User Information associated with your Courses.
We will periodically send you free newsletters and emails that directly promote the use of the Versal Services and will, where required by law, obtain your consent. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly at help@versal.com. We may still send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.
All Customers may review, update, correct or delete the personal data in their Account Profile (including any imported contacts) by making these changes in the account settings or by contacting us help@versal.com , and we will use commercially reasonable efforts to honor your request. If you completely delete all of your personal data your Account may become deactivated. Deleting your account and associated data will result in the loss of your courses, and learners will no longer be able to access them.
Customers with Versal Pro accounts and Organization account may set Courses to private before they are published, and may change public Courses to private after they have been published, by modifying the settings in your course management options.
Individuals in the EU may have some or all of the following rights regarding their personal data:
You have the right to obtain a copy of your personal data together with information about how and on what basis that personal data is processed;
You have the right to rectify inaccurate personal data (including the right to have incomplete personal data completed);
You have the right to erase your personal data (in limited circumstances, such as where it is no longer necessary in relation to the purposes for which it was collected or processed; you have withdrawn your consent (where the data processing was based on consent; following a successful right to object; it has been processed unlawfully; or to comply with a legal obligation to which we are subject.). We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary: for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims);
You have the right to restrict processing of your personal data under certain circumstances such as where its accuracy is contested, to allow us to verify its accuracy; the processing is unlawful, but you do not want it erased; it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims;
You have the right to port your data in machine-readable format to a third party (or to you) when we justify our processing on the basis of your consent or the performance of a contract with you and the processing is carried out by automated means;
You have the right to withdraw your consent to our processing of your personal data (where that processing is based on your consent);
You have the right to object, on grounds relating to your particular situation, at any time to any processing of your personal data for which we have justified on the basis of a legitimate interest (including profiling) or to perform a contract with you. You also have the right to object at any time to any processing of your personal data for direct marketing purposes, including profiling for marketing purposes.
You also have the right to lodge a complaint with your local supervisory authority for data protection.
If you wish to exercise any of the above rights please contact us at help@versal.com. We may request proof of identity. If you contact us regarding Customer Content or End User Information, for which we are a data processor, we will attempt to refer your request to the relevant Customer.
We retain your personal data only for as long as required to fulfill the purposes for which it was collected; generally, this means Versal will delete Account Information within seven (7) years of deletion of the account, unless we are required to retain the personal data in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required. In specific circumstances, we may also retain your personal data for longer periods of time corresponding to a statute of limitation, so that we have an accurate record of your dealings with us in the event of any complaints or challenges.
Versal is headquartered in the United States, and has operations, entities and service providers in the United States and throughout the world. As such, we and our service providers may transfer your personal data to, or access it in, jurisdictions (including the United States, Singapore and India) that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it, including through appropriate written data processing terms and/or data transfer agreements, and by executing with Customers the standard contractual clauses as approved by the European Commission (the form for the standard contractual clauses can be found here).
We have implemented appropriate safeguards to protect the personal data we collect from alteration, destruction, misuse and unauthorized access or disclosure, but we can’t guarantee the security of any information. We encourage you to also take steps to secure your information, such as by choosing a strong password and limiting access to your computer and browser by signing off after you have finished using the Services.
We may change this privacy policy from time to time. We will post the revised privacy policy on the Versal website at versal.com/privacy, and will either send you a notice via the email address specified in your registration and/or by posting a prominent notice of any material changes on the Versal website prior to it taking effect so you are always aware of what information we collect, and what we are doing with it. Your continued use of the Versal Services will then be subject to the updated privacy policy.
If you have any questions regarding the Versal privacy policy or our practices, contact us at help@versal.com or at: