Privacy Policy

 

This privacy policy has been compiled to better serve those who are concerned with how their 'Personally identifiable information' (PII) is being used online. PII, as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.
Viewlance Inc is a leading international mining group structure as a single economic entity, called the Viewlance Inc Group.
This Privacy Policy applies to all Viewlance Inc staff and all the companies in the Viewlance Inc Group (which may be described as "Viewlance Inc", "Group businesses", "we" or "us" in this Privacy Policy also).

Structure
This Privacy Policy is in two parts. It contains:
•    Viewlance Inc's Data Privacy Standard which includes Data Privacy Principles that apply whenever and wherever Viewlance Inc collects and processes personal data; and
•    Online privacy and cookies statement, which sets out additional information about your privacy if you use this website

What personal information do we collect from the people that visit our website or app?

When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address, mailing address or other details to help you with your experience.

 

When do we collect information?

 

We collect information from you when you register on our site, place an order, subscribe to a newsletter, fill out a form or enter information on our site.


How do we use your information?

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
      • To personalize user's experience and to allow us to deliver the type of content and product offerings in which you are most interested.
      • To improve our website in order to better serves you.
      • To allow us to better service you in responding to your customer service requests.

 

Do we use 'cookies'?

 

Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to:
      • Understand and save user's preferences for future visits.
      • Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser's Help menu to learn the correct way to modify your cookies.

 

If users disable cookies in their browser:

 

If you disable cookies off, some features will be disabled It will turn off some of the features that make your site experience more efficient and some of our services will not function properly.

However, you can still browse our website and place orders.


Third Party Disclosure
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information.

Third party links
We do not include or offer third party products or services on our website.

Questions and contact information
If you have any questions or complaints about your privacy or wish to exercise your rights as a data subject, please refer to Data Privacy Principle 9 in the Data Privacy Standard and:
•    contact the data privacy co-ordinator for your Viewlance Inc Group business;
•    contact your local Viewlance Inc office; or
•    email us at [email protected] Your correspondence will be forwarded to the Viewlance Inc data privacy co-ordinator for the relevant business unit within Viewlance Inc.
This Privacy Policy may be updated from time to time. This Privacy Policy was last updated on 13 February 2015.
Data privacy standard
Introduction
What does this Standard do?
The Data Privacy Standard sets out the minimum rules (Data Privacy Principles) that apply whenever and wherever Viewlance Inc collects and processes personal data. Note that:
•    Personal data means all information relating to any identifiable individual.
•    Process and processing covers everything we might do with personal data.
The Data Privacy Principles reflect the common principles and requirements under data privacy laws (sometimes known as data protection laws or privacy laws) in the countries where Viewlance Inc operates.
Why is compliance with this Standard important?
At Viewlance Inc, the lawful and correct handling of personal data is critical. At its simplest, people need to be able to trust us to respect their privacy and how we handle their personal data when working with us or doing business with us.
In addition, we need to comply with privacy and data protection laws around the world. Applying the Data Privacy Principles in this Data Privacy Standard helps us to do this.
Who does this Standard apply to?
This Standard applies to everyone who works for Viewlance Inc, and to each Viewlance Inc Group business. We must comply with the Data Privacy Principles and also with local laws that apply to the processing of personal data. If there is a conflict between the requirements under the Data Privacy Principles and local laws, you should comply with the most stringent requirement. Your Data Privacy Co-ordinator, Viewlance Inc Compliance or Viewlance Inc Legal can advise you if you're unsure. Any variance from the Data privacy standard must be approved by the Global Head of Compliance.
Where can I obtain more information?
More detailed guidance on data privacy is available in the Viewlance Inc Data Privacy Manual. This is a "how to" guide that has been developed for Data Privacy Co-ordinators and other Viewlance Inc staff who process personal data as part of their job, or who need a more detailed understanding of data privacy at Viewlance Inc.
If you have questions about data privacy at Viewlance Inc, you should contact the Data Privacy Co-ordinator for the Group business that you work for or deal with. A listing of Data Privacy Co-ordinators is available from the data privacy page on the Prospect portal (Compliance community). If you are external to Viewlance Inc or have a data privacy question, you can send an email to [email protected]
Data privacy principles
The following Data Privacy Principles reflect the minimum rules that apply to the collection and processing of personal data at Viewlance Inc.
Data Privacy Principle 1: We limit our processing of personal data
We must only collect, use, disclose, store and otherwise process personal data for specific and limited purposes. In particular, we can only process personal data:
•    for the legitimate business purpose we collected it for (eg as explained in a collection notice);
•    for a related purpose(s) that the data subject would reasonably expect;
•    for other purposes that the data subject (the person that the data relates to) consents to; or
•    if the processing is required in order to comply with our legal obligations.
We can't process personal data unless this test is satisfied.
A stricter test applies when sensitive information is processed (see Data Privacy Principle 5: We are careful with sensitive information and Government-issued numbers).
Data Privacy Principle 2: Our collections are lawful and fair and we only collect what we need
Our collections of personal data need to be lawful, fair and necessary for a specific, legitimate business purpose. We must collect only that amount of personal data that we need in order to conduct business. Personal data collections must not be excessive.
Data Privacy Principle 3: We are open about what we collect
If we need personal data, we will, where practicable, collect it directly from the data subject.
We will notify data subjects that we're collecting their personal data, by providing a collection notice either when personal data is collected, or as soon as possible afterwards.
A general overview of the types of personal data collected by Viewlance Inc, the purposes of collection and how personal data is stored,
Data Privacy Principle 4: We check data quality
When we collect and process personal data, we should take reasonable steps to ensure that the personal data is accurate, complete and up to date.
There are risks for both Viewlance Inc and data subjects if we use inaccurate, incomplete or out of date personal data, particularly if it is relied upon to make decisions that affect data subjects. The more sensitive the data, the greater the risk to the data subject if poor quality personal data is used or disclosed.
Collecting personal data directly from the data subject (under Data Privacy Principle 3: We are open about what we collect) is a way to ensure the quality of personal data. If we intend to use personal data that is of the type that can change over time, its currency and accuracy should be checked.
Data Privacy Principle 5: We are careful with sensitive information and Government-issued numbers
Sensitive information is a type of personal data that is of a particularly private nature and includes (among other things) personal data about a person's race, ethnic origins, trade union membership and health information.
We must ensure that sensitive information is collected only when absolutely necessary and only if:
•    the data subject consents; or if
•    the collection is
•    required by law;
•    necessary to prevent or lessen a serious and imminent threat to the life, health or safety of any person; or
•    necessary for legal proceedings.
We can only process sensitive information for the purposes notified to the data subject (when we obtained consent) or for the other specific purposes listed above.
Government-issued numbers also need to be processed with care. We must only process Government-issued numbers as permitted under local laws.
We must never use a Government-issued number (in relation to a data subject) as the basis for how we organize personal data about a data subject. Government-issued numbers should not be our only way of identifying a data subject.
Data Privacy Principle 6: We take care when we share personal data
We must ensure that our disclosures of personal data are adequately protected and lawful. This is summarized below; but if you have questions please contact your Data Privacy Co-ordinator.
Disclosures outside the Viewlance Inc Group
If we need to disclose personal data outside the Viewlance Inc Group (for example, to an external service provider), we must ensure that:
•    the disclosure is protected by contractual data privacy clauses approved by Viewlance Inc Compliance or Viewlance Inc Legal; or
•    the relevant data subjects have consented to the disclosure.
Viewlance Inc Compliance or Viewlance Inc Legal should also confirm if disclosures are required by law.
Disclosures within the Viewlance Inc Group
Disclosures within the Viewlance Inc Group are protected by the Viewlance Inc Data Transfer Deed. Company secretarial and each Group business need to ensure that new companies sign up to the Data Transfer Deed.
International disclosures
As a global company, we need to disclose personal data across national borders. However we must ensure such disclosures comply with data privacy laws.
More information about the countries where Viewlance Inc operates, and the location of key external service providers (data processors)
Data Privacy Principle 7: We must secure personal data
Personal data must be kept secure from unauthorized access, loss, destruction, misuse, modification or disclosure. This applies to personal data whether in hard copy form (eg paper) or in electronic form (eg in databases). The key rules are:
•    access to personal data about other people should be on a "need to know" basis only; and
•    each Group business must implement the Viewlance Inc Information security standards (administered by Global security) to ensure that appropriate physical, technical and organizational security measures are in place at all stages of the personal data 'life cycle'.
Data Privacy Principle 8: We don't keep personal data forever
Personal data must be kept only for as long as it is needed for proper business purposes, or for the time required or permitted under local laws (whichever is the shorter). After such time, records containing personal data must be securely destroyed (in the case of physical records) or permanently deleted (in the case of electronic records).
Data Privacy Principle 9: We respect data subject rights
Data subjects have the right to:
•    seek access to personal data that Viewlance Inc holds about them;
•    seek correction of inaccurate, incomplete or out of date personal data;
•    be provided with information about how their personal data is processed;
•    ask for processing of their personal data to cease (particularly if the processing is likely to cause damage or distress, or if the processing is for direct marketing purposes);
•    be notified if the Group business has made a decision about the data subject that is based on automated data processing alone (so that the data subject can ask for a review of the decision, if necessary); and
•    Complain about the processing of their personal data.
Exceptions can apply in the case of access and correction rights, and Viewlance Inc will review each request on a case by case basis.
More information about how data subject rights can be exercised (and relevant procedures)
Under some data privacy laws Viewlance Inc is required to give data subjects the option of remaining anonymous or using a pseudonym (if practicable).
Data Privacy Principle 10: We are accountable for compliance
Each Group business must appoint at least one person to act as its Data Privacy Co-ordinator, and notify Viewlance Inc Compliance when such appointments are made.
The Data Privacy Co-ordinator should be the first point of contact for data privacy questions from the Group business that she or he represents.
The Data Privacy Co-ordinator is accountable for data privacy compliance by the Group business they represent, and should have an understanding of the personal data processing that is carried out by that Group business. Data Privacy Co-ordinators must have sufficient authority and resources to conduct their duties under the Data privacy standard.
Everyone at Viewlance Inc who processes personal data must comply with the Data privacy standard, and is accountable for compliance with data privacy laws. If you have questions about data privacy, ask your Data Privacy Co-ordinator.
Data Privacy Principle 11: We train our people
Everyone at Viewlance Inc who processes personal data as a significant part of their role should receive data privacy training and be provided with information about how to access this Data privacy standard. Data Privacy Co-ordinators should receive additional training designed for their role. Training will be provided by Viewlance Inc Compliance and must be completed as directed by Viewlance Inc Compliance. More information is available in the Data Privacy Manual.
Data Privacy Principle 12: We don't spam
One way we limit how we process personal data is to limit how we use personal data to send marketing communications. This is a broad term (reflecting the approach under anti-spam legislation in countries where Viewlance Inc operates), but does not include Viewlance Inc communications to staff.
All marketing communications (however distributed) must:
•    clearly identify the relevant Group business or Group company as the sender, and how it can be contacted;
•    be sent with the consent of the recipient/data subject (which may be able to be implied from an existing business relationship or shareholding);
•    Contain an unsubscribe or opt out facility. Opt outs must be acted upon and records amended accordingly.
Breaches of Data privacy standard
Breaches of the Data privacy standard or local data privacy laws may be reported to:
•    your manager or supervisor;
•    your local compliance manager or your Data Privacy Co-ordinator;
•    a Viewlance Inc lawyer;
•    Viewlance Inc Compliance; or
•    via Speak-OUT
Breach reports need to be immediately brought to the attention of the Data Privacy Co-ordinator for the relevant Group business and Viewlance Inc Compliance. Viewlance Inc Compliance will work with the Data Privacy Co-ordinator plus the compliance manager for the Group business, Viewlance Inc Legal and Global security to respond to the identified breach.
Review of Data privacy standard
This Standard will be reviewed at least once every three (2) years.
Glossary
Collection notice: a notice that needs to be provided to data subjects when we collect their personal data, or as soon as possible thereafter.
Data Privacy Co-Ordinator: a person appointed under Data Privacy Principle 10.
Data Privacy Principles: the principles in the Data Privacy Standard that Viewlance Inc Group companies and staff must apply when processing personal data.
Data subject: the individual to whom personal data relates.
Group business: includes all companies, product groups, business units, global functions and corporate offices in the Viewlance Inc Group.
Legitimate business purpose: a purpose that is directed at Viewlance Inc achieving its business objectives and that complies with all relevant laws and regulations.
Marketing communications: means communications and publications that have a purpose of marketing or promoting Viewlance Inc or its products, but does not include staff communications.
Personal data: all information relating to any identifiable individual (whether living or deceased).
Processing: all actions taken in relation to personal data including collecting, using, disclosing, recording, organizing, storing, transferring, amending, deleting, destroying, retrieving, accessing, hosting or otherwise handling .
Viewlance Inc Group: all the businesses which are wholly or majority owned or managed by Viewlance Inc or Viewlance Inc Pvt Limited (whether directly or indirectly).
Sensitive information: personal data (including information or an opinion) about an individual's racial or ethnic origin, political opinions and memberships, religious or philosophical beliefs or associations, trade union membership, criminal record, health or the health services they have received.

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