VMware Privacy Program

Our comprehensive privacy program enables you to feel confident that your personal data is kept private and processed responsibly.

Protecting Personal Data as a Service Provider

How VMware, as a processor, enables you to comply with data protection and privacy requirements.

Contractual Agreements

Review VMware contractual obligations for the ongoing protection of the personal data you submit to its services.

Sub-Processors

Explore the list of third parties VMware engages with to perform services on its behalf and sign up to be notified if the list changes.

VMware Products and Services

The personal data VMware collects, and processes varies depending on which services you purchase. Read through the privacy datasheets and UEM disclosure to discover the personal information VMware processes in relation to its service offerings.

Protecting Personal Data as a Business

How VMware, as a controller, complies with data protection and privacy requirements.

Privacy Notices

VMware privacy notices detail the personal information collected, how it is used, how long it is stored, and who has access to it.

Privacy Culture at VMware

VMware privacy policies and training programs ensure its employees know how to protect your data. Its Data Protection Officer is also consulted with as needed.

Privacy by Design and Records of Processing

VMware has a comprehensive privacy program that includes privacy reviews, records of processing activities, and transfer impact assessments. 

Marketing Preferences and Data Subject Rights

VMware respects your privacy, offering choice and control over your personal information.

Frequently Asked Questions

“Customer Content” (or “Your Content”) is any content that you, as a customer, or your users upload into a Cloud Service for processing, storage, or hosting in connection with your account. In the context of Support Services, “Customer Content” is any content you provide to VMware as a part of Support Services. The definition of “Customer Content” can be found in the VMware General Terms. For example, Customer Content includes data that you or your users store in Workspace ONE. Importantly, your account information, including names, usernames, phone numbers, and billing information associated with your account, is not included in the definition of “Customer Content”, nor any information VMware collects in connection with your use of its Cloud Services. Rather, VMware will handle that information in accordance with its Privacy Notice.

You always retain ownership of Customer Content. You determine which VMware Cloud Services you use to process, store, and host Customer Content, and what information you upload into the Cloud Service as Customer Content. Also, VMware will not access or use Customer Content for any purpose except as necessary to provide the Cloud Service to you or as set forth and permitted in its VMware General Terms with you. Lastly, VMware does not use Customer Content for marketing or advertising.

VMware engages and uses third parties to perform services on its behalf in connection with the provision of VMware service offerings. In connection with the engagement of third parties who process personal data as a sub-processor (as those terms are defined in Data Processing Addendum), VMware has implemented the following processes and procedures:

  1. Contractual commitment and international data transfers: VMware enters into data processing agreements with all its sub-processors, which require the sub-processors to maintain proper privacy, security and confidentiality of personal data on terms that are substantially similar to the contractual commitments VMware makes to its own customers in the Data Processing Addendum. VMware relies on the EU Standard Contractual Clauses unless there is another legitimate data transfer mechanism in place and the sub-processor makes appropriate contractual commitments.

  2. Privacy review process and privacy by design: VMware has established a centralized end-to-end third-party vendor management process to onboard new suppliers, including initiating, conducting and tracking third-party privacy and security reviews using centralized tools to assist with its compliance efforts. The VMware Privacy Team conducts detailed privacy reviews of the services provided by Sub-processors, including determining the categories of personal data processed and the processing purposes. The reviews include the implementation of privacy controls for mitigating the risks associated with sub-processors’ access to and processing of Personal Data and ensuring regulatory compliance.

  3. Security review process: VMware maintains a policy and process for conducting security reviews of sub-processors. The VMware Security Team conducts an initial security review of any new sub-processor, and ongoing monitoring based on the identified security risk level.

  4. List of sub-processors and notification of new sub-processors: VMware maintains a list of the sub-processors used by individual service offerings and in relation to the Support & Subscription Services. VMware provides prior notice of any new engagement of a sub-processor to customers that have subscribed to receive notification for a specific service. 

VMware has an internal process for tracking, analysing and assessing new laws, regulations, binding guidance and case law that may apply to VMware whether in its provision of its services or in the operation of its business.  The Privacy Team relies on outside counsel, external privacy research tools and law firm news alerts to understand when new laws and regulations are enacted. 

Once it is determined that a specific privacy law applies to VMware, such as was the case with laws in China, Japan, California, Colorado, Virginia, and Utah, for example, VMware tracks the legal requirements and implements a project plan to ensure compliance. As part of the implementation process, the VMware Privacy Team engages relevant internal stakeholders, and identifies the processes and controls that need updating to comply with the new legal requirements.  The VMware Privacy Team relies on its eco-system of Privacy Councils (driven by functional area such as Marketing, HR, Sales) within the company to assist with the implementation of new or changed laws in a timely and efficient manner.

The VMware Privacy Team also leverages its standard privacy training and other company trainings to ensure all its employees and contractors are properly trained on any new legal requirements that may impact their business function. For example, as part of VMware’s regulatory compliance with its Binding Corporate Rules for Processors, VMware implemented the necessary trainings via its annual mandatory Security and Awareness training, as well as updated its Business Code of Conduct to reflect the new requirements.

Security of its Cloud Services is of the utmost importance to VMware. For more information on how VMware secures its Cloud Services, see the Trust Center Security page. VMware maintains an information security management program that is aligned with the ISO 27001 standard, and reviewed at least annually to ensure appropriate controls, practices and procedures are in place.

In using VMware Cloud Services, you are responsible for configuring and implementing the necessary technical, organizational, and administrative controls to enable you to comply with any laws applicable to your use of the Cloud Service, which may depend on the types of data you choose to process using the service. Your responsibilities relating to the security of your Customer Content are set forth in the applicable agreement and include (a) controlling access you provide to your users, (b) configuring the Cloud Service appropriately, (c) ensuring the security of Customer Content while it is in transit to and from the Cloud Service, (d) using encryption technology to protect Customer Content as you deem necessary, and (e) backing up Customer Content.

How We Protect Personal Data as a Service Provider

As a processor, VMware has developed a comprehensive privacy program to enable you, as a controller, to comply with data protection law in your use of the service.

Contractual Commitments

These privacy agreements supplement the VMware General Terms, available at VMware ONE Contract Center.
Data Processing Addendum

Data Processing Addendum

VMware contractual commitments to protect the security, confidentiality, and integrity of your personal data.

Sub-Processors

VMware follows defined processes and procedures to protect your personal data when engaging with third parties who perform services on its behalf.

Standard Contractual Clauses for International Data Transfers

VMware enters into data processing agreements with all sub-processors, requiring them to maintain the privacy, security, and confidentiality of personal data on terms substantially similar to the contractual commitments in our Data Processing Addendum. To ensure safe, secure and legal data transfers from the EEA, Switzerland or the UK, and to protect any subsequent onward transfers, VMware relies on the EEA Standard Contractual Clauses (“EEA SCCs”), UK International Data Transfer Agreement or UK Addendum to EEA SCCs unless another legitimate data transfer mechanism is in place.

Sub-Processor List and Notifications

VMware maintains a list of the sub-processors used by each VMware service.

 

You can receive notice when a new sub-processor is engaged by your service by subscribing to receive notification.

VMware Products and Services

VMware provides datasheets to help you understand the personal data processed by its services, and additional resources that outline its unified endpoint management and data usage programs.
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Workspace ONE Unified Endpoint Management

VMware Workspace ONE Unified Endpoint Management is a single solution that offers a scalable approach to process automation, end-user device and application management, and enterprise level security. To assist customers in complying with their transparency obligations under law, VMware makes available the Workspace One Disclosure. Customers, in their capacity as a controller, can provide a privacy notice to its users based on this disclosure and the customer’s configuration, use and deployment of Workspace One. To learn more, access the Workspace ONE Unified Endpoint Management (UEM) product page.

Improving our Products and Services

VMware collects information about customer organizations’ use of VMware products and services for its analytics and customer experience improvement programs, designed to improve its offerings and your customer experience.

Privacy by Design and Records of Processing

Privacy reviews, transfer impact assessments and records of processing activities are integral components of the VMware privacy program, designed to mitigate risk and ensure compliance.

Privacy Reviews

VMware Products and Services

VMware has implemented a privacy by design framework in the lifecycle of its on-premise products and hosted services.

The privacy by design framework includes:
 

  • Documented instructions for submitting a product or service through a privacy review.
  • Designated legal counsel to conduct privacy reviews.
  • Data processing impact assessments (as may be required).
  • General privacy requirements for designing products and services in compliance with applicable data protection and privacy laws.

Third-Party Vendors

VMware has established a centralized end-to-end third-party vendor management process to onboard new suppliers.

 

The VMware Privacy Team conducts privacy reviews of the services provided by vendors, including:
 

  • Determining the categories of personal data processed and the processing purposes.
  • Implementing privacy controls to mitigate the risks associated with vendors’ access to and processing of personal data to ensure regulatory compliance.

Transfer Impact Assessments

VMware conducts transfer impact assessments (TIAs) on personal data transferred from the EEA, Switzerland, or the UK to third countries which have not been granted adequacy status.

Its internal process for conducting TIAs follows the European Data Protection Board (EDPB) guidance and the UK Information Commissioner’s Office’s International Transfer Risk Assessment and Tool.

This includes:
 

  • Undertaking a country level analysis.
  • Gathering additional information from VMware vendors to assess government access.
  • Conducting TIAs as part of the privacy review for VMware products and services, third-party sub-processors, and corporate functions.

For more information, including how VMware handles government access requests and the likelihood of such requests, refer to the TIA FAQ.

Records of Processing Activities

Records of Processing Activities (RoPA) outline what personal data VMware holds as an organization and where. Created through information auditing and data-mapping, RoPA is a comprehensive record of VMware personal data processing activities and includes information regarding:
 

  • Data categories
  • Data subjects
  • Purpose of and lawful basis for processing
  • Data recipients
  • Retention schedules
  • Description of technical and organizational measures and documentation of safeguards
  • Processing activities carried out by our sub-processors

VMware RoPAs are regularly reviewed and updated. VMware will provide access to data protection authorities as required to comply with regulatory obligations.

Privacy Culture at VMware

We make choices every day affecting data privacy. VMware policies, training, and Data Protection Officer consultation ensures every decision made is the right one.

Privacy Policies & Practices

VMware has comprehensive policies and practices in place to ensure personal data is adequately protected and to help identify, prevent, and resolve security vulnerabilities in its products and services. These policies and practices are continually reviewed and updated.

Privacy Training Program

VMware employees complete mandatory privacy training on a regular basis, both general and role specific. Confidentiality agreements are also required for all employees.

Data Protection Officer

The VMware Privacy Team engages a Data Protection Officer as appropriate in issues related to the protection of personal data, regulatory obligations and compliance, data protection impact assessments, and as the point of contact for supervisory authorities.

Take Control of Your Data Privacy

VMware honors the choices you make to protect your personal data and respects your privacy rights.
Marketing Communication Preferences

Update your preferences for advertising and promotional communications, including event invitations, newsletters, and learning program offerings.

Privacy Contact Form

Contact VMware for answers regarding your personal data or to exercise your rights under privacy law.

Cookie Management

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