Privacy Policy Table of Contents

• What this Privacy Policy Covers
• Personal Data
  • Categories of Personal Data We Collect
  • Categories of Sources of Personal Data
  • Our Commercial or Business Purposes for Collecting Personal Data
• How We Share Your Personal Data
• Tracking Tools, Advertising, and Opt-Out
• Data Security and Retention
• Personal Data of Children
• California Resident Rights
• Other State Law Privacy Rights
• Privacy Notice for EU & UK Residents
• Changes to this Privacy Policy
• Contact Information

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

To the extent that the Site and Service is available to individuals located in the European Economic Area or the United Kingdom (including Gibraltar), this Privacy Policy sets out our practices and obligations under the General Data Protection Regulation 2016/679 (the “GDPR”), to the extent applicable. If an organization with which you are associated (an “Organization”) signs up to use our Service, we may receive personally identifiable information about you in connection with our provision of the Service to your Organization. To the extent we process (as defined below) that personally identifiable information solely in order to provide the Service to your Organization, under the GDPR, to the extent applicable, we will act as a processor (as defined in the GDPR) on behalf of your Organization in respect of that personally identifiable information; this Privacy Policy will not apply to the processing of that personally identifiable information and your Organization will act as a controller (as defined in the GDPR) in respect of that personally identifiable information and is responsible for obtaining all necessary consents and providing you with all requisite information as required by applicable law. To the extent we process your personally identifiable information for any other lawful business purpose of ours, under the GDPR, to the extent applicable, we will act as a controller of such personally identifiable information and this Privacy Policy will apply to the processing of such personally identifiable information. For clarification but not limitation, information we process for our lawful business or commercial purposes, such as for product development or sales and marketing, is not processed solely on behalf of your Organization.

As used in this Privacy Policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within Vartopia or among our affiliates within the United States or internationally.

Personal Data

Categories of Personal Data We Collect.

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You

• When you provide such information directly to us.
  • When you create an account on the Site or through the Services or use our interactive tools and Services.
  • When you voluntarily provide information in free-form text boxes through the Site or Services or through responses to surveys or questionnaires.
  • When you send us an email or otherwise contact us.
• When you use the Site or Services and such information is collected automatically.
  • Through Cookies (defined in the “Tracking Tools, Advertising, and Opt-Out” section below).
  • If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
  • If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.

Third Parties

• Vendors
  • We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
  • We may use vendors to obtain information to generate leads and create user profiles.
• Customers
  • We receive information about you from some of our customers who provide information regarding users who have the ability to post content associated with their account for our products or services.
• Advertising Partners
  • We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.
• Social Networks
  • If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.

Our Commercial or Business Purposes for Collecting Personal Data

Providing, Customizing and Improving the Services

• Creating and managing your account or other user profiles.
• Processing orders or other transactions; billing.
• Providing you with the products, services or information you request.
• Providing Customers with the products, services or information they request.
• Meeting or fulfilling the reason you provided the information to us.
• Providing support and assistance for the Services.
• Improving the Services, including testing, research, internal analytics and product development.
• Personalizing the Services, website content and communications based on your preferences.
• Doing fraud protection, security and debugging.
• Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).

Marketing the Services

• Marketing and selling the Services.

Corresponding with You

• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about the Services.
• Sending emails and other communications according to your preferences or that display content that we think will interest you.

Meeting Legal Requirements and Enforcing Legal Terms

• Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
• Protecting the rights, property or safety of you, Vartopia or another party.
• Enforcing any agreements with you.
• Responding to claims that any posting or other content violates third-party rights.
• Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

How We Share Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

• Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
  • Hosting, technology and communication providers.
  • Security and fraud prevention consultants.
  • Support and customer service vendors.
  • Product fulfillment and delivery providers.
  • Payment processors.
    • Our payment processing partner collects your voluntarily-provided payment card information necessary to process your payment.
    • Please see terms of service and privacy policy for information on its use and storage of your Personal Data.
• Customers. These parties are businesses that you have a relationship, that we also have a relationship with, and our Sites provide you the ability to connect with our Customers and share information.
• Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include:
  • Ad networks.
  • Data brokers.
  • Marketing providers.
• Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
  • Companies that track how users found or were referred to the Services.
  • Companies that track how users interact with the Services.
• Business Partners. These parties partner with us in offering various services. They include:
  • Businesses that you have a relationship with.
  • Companies that we partner with to offer joint promotional offers or opportunities.
• Parties You Authorize, Access or Authenticate
  • Third parties you access through the services (such as Customers).
  • Social media services.
  • Other users.

Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

Tracking Tools, Advertising and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit https://www.allaboutcookies.org/ [or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union].

Data Security and Retention

We use a variety of security technologies and procedures to help protect your Personal Data from unauthorized access, use or disclosure. We secure the Personal Data you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Data is protected using appropriate physical, technical and organizational measures. For more on Security at Vartopia or to report a Security concern please contact us at [email protected].

Your account is protected by a password for your privacy and security. If you access your account via a third party site or service, you may have additional or different sign-on protections via that third party site or service. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Site or Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at [email protected].

California Resident Rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at [email protected].

Compliance & Governance

Vartopia complies with the EU-U.S. Data Privacy program Framework (EU-U.S. DPF), the UK Extension to the EU-US DPF, and the Swiss-U.S. Data Privacy program Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Vartopia has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework program Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union, the UK and Gibraltar in reliance on the EU-U.S. DPF and the UK Extension. Vartopia has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework program Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the UK Extension to the EU-U.S. DPF Principles, and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/

Vartopia is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

Pursuant to the Data Privacy program Framework (DPF) EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. Furthermore, you have the right to demand deletion of personal data that has been handled in violation of the Data Privacy program Framework (DPF) Principles. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under DPF should direct their query to [email protected]. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to [email protected].

In certain situations, 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. Vartopia’s accountability for personal data that it receives in the United States under the Data Privacy program Framework (DPF) and subsequently transfers to a third party is described in the Data Privacy program Framework (DPF) Principles. In particular, Vartopia remains responsible and liable under the DPF Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Vartopia proves that it is not responsible for the event giving rise to the damage.

In compliance with the DPF Principles, Vartopia commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to DPF European Union, United Kingdom, and Swiss individuals with DPF inquiries or complaints should first contact Vartopia by email at [email protected].

• In compliance with the EU-US Data Privacy Framework Principles, Vartopia commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the DPF Principles. European Union, UK, and Swiss individuals with DPF inquiries or complaints should first contact Vartopia.
• Vartopia has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.
• If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2

How to Contact Us

In compliance with the DPF Principles, Vartopia commits to resolve complaints about our collection or use of your personal information.  EU, UK, and Swiss individuals with inquiries or complaints regarding our DPF policy should first contact Vartopia using the information below.

• If you have any questions or comments about this Global Privacy Notice, Vartopia’s privacy practices or if you would like us to update information or preferences you provided to us, or log a complaint, please click here.
• You also may e-mail us at: [email protected]; or write to us at:

  Global Privacy Officer
  Vartopia, LLC
  970 West Broadway
  Jackson, WY 83001, US

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

• The categories of Personal Data that we have collected about you.
• The categories of sources from which that Personal Data was collected.
• The business or commercial purpose for collecting or selling your Personal Data.
• The categories of third parties with whom we have shared your Personal Data.
• The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Exercising Your Rights

To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides the following information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

In compliance with the DPF Principles, Vartopia commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our DPF policy should first contact Vartopia using the information below.

• If you have any questions or comments about this Global Privacy Notice, Vartopia’s privacy practices or if you would like us to update information or preferences you provided to us, or log a complaint, please click here.
• You also may e-mail us at: [email protected]; or write to us at:

You may submit a Valid Request using the following methods:

• Email us at: [email protected]
• Submit a form at this address:

Global Privacy Officer
Vartopia, LLC
970 West Broadway
Jackson, WY 83001, US

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Personal Data Sales Opt-Out and Opt-In

We will not sell your Personal Data, and have not done so over the last 12 months. To our knowledge, we do not sell the Personal Data of minors under 16 years of age. If this practice should change in the future we will update this policy to provide information on how to opt-out or opt-in, to that data transfer, as applicable.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at [email protected].

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at [email protected] with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

Privacy Notice for EU and UK Residents

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.

Vartopia may process Personal Data of our customers’ end users or employees in connection with our provision of services to customers, and we are the processor of any such Personal Data. Please contact your employer, the controller party. in the first instance to address your rights with respect to such data. Vartopia may also be the controller of Personal Data processed in connection with the Services.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at [email protected].

Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

Personal Data use and Processing Grounds

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

• Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service or Agreement with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
• Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
  • Examples of these legitimate interests include:
    • Operation and improvement of our business, products and services
    • Marketing of our products and services
    • Provision of customer support
    • Protection from fraud or security threats
    • Compliance with legal obligations
    • Completion of corporate transactions
• Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
• Other Processing Grounds: From time to time, we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Sharing Personal Data

The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.

EU Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email [email protected]. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by going to your account settings.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by going to your account settings.
• Erasure: You can request that we erase some or all of your Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint: You have the right to lodge a complaint about Vartopia’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through Vartopia and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Vartopia in the U.S. and will be hosted on U.S. servers, and you authorize Vartopia to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to (i) a data processing agreement incorporating standard data protection clauses promulgated by the European Commission, (ii) binding corporate rules for data protection that align with the GDPR’s requirements, or (iii) adherence to an industry- or technology-specific approved code of conduct blessed by the European Commission.

Moreover, Vartopia remains committed to the Principles of the EU-U.S. DPF Framework set forth by the U.S. Department of Commerce regarding the collection and use of Personal Data transferred from the EU. These Principles are (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU in reliance on the DPF.

On July 16, 2020, the Court of Justice of the European Union issued a judgment in the Schrems II case invalidating the EU-U.S. DPF as a compliance mechanism for transfers of personal data from the EU to the U.S. The U.S. Department of Commerce has stated that it will continue to administer the DPF, and individuals can still file complaints with the Federal Trade Commission (FTC) and/or local supervisory authorities. The FTC can still enforce the DPF against current and former participating companies. We remain committed to our obligations under the DPF and will continue to protect our customers’ data in accordance with those obligations.

Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on https://www.vartopia.com. by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to [email protected], and we will try to resolve your concerns.