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Global Privacy Policy

Effective Date: February 23rd, 2021

Vartopia, LLC and its affiliates (collectively, “Vartopia,” “we,” “us,” or “our”) respect your privacy. This Global Privacy Notice describes the types of personal information we collect, how we use the information, with whom we share it, and the choices you can make about our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices.

Vartopia entities responsible for the collection and use of your personal information for the purposes described in this Global Privacy Notice are indicated in the How to Contact Us section of this document.

Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements.

Program Interfaces and Images

Personal Information We Collect

Vartopia may obtain information about you from various sources.

As a processor of business transactions and provider of related services, we obtain a limited amount of personal information about you from Technology Manufactures, Distributors, Resellers and other entities in connection with your transactions.

We also may obtain information about you from companies that use or facilitate the use of other Vartopia products or services and from publicly available information systems.

In addition, you may choose to submit information directly to us via several methods, including: (i) on our websites, (ii) in response to marketing or other communications, (iii) through social media, (iv) by signing up for a Vartopia product or service, (v) through participation in an offer, program or promotion, or (vi) in connection with an actual or potential business or employment relationship with us. You may also choose to consent to third parties disclosing information about you to us that those third parties have collected.

Images may not be reproduced without written permission. All images are the property of Vartopia and/or its respective clients. Any interface examples (designs, layouts, functionality, processes, images, source code, compiled code, workflows etc.) or demos may NOT be copied or duplicated in any form. All content on this Website is the exclusive Intellectual Property and Copyright of Vartopia 1996-2020. You are violating Copyright laws if you engage in any such activity and will be fully prosecuted of the law for any such violation.

The types of personal information we may obtain, or you may choose to provide include:

  • Contact information (such as name, e-mail address, and phone number)
  • Business contact information (such as job title, department and name of organization)
  • Username and password
  • Contact information for business associates or other people you would like us to contact
  • Content you provide (such as documents and comments)
  • Content you make available through social media accounts or memberships with third


  • Mobile device unique identifier
  • Geo-location data
  • Other information (such as system user preferences, and language preference

    We, our service providers and partners collect certain information by using automated means, such as cookies and web beacons, when you interact with our advertisements, mobile applications, or visit our websites, pages or other digital assets. The information we collect in this manner may include IP address, browser type, operating system, referring URLs and information on actions taken or interaction with our digital assets. A “cookie” is a text file placed on a computer’s hard drive by a web server. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, is used to transmit information back to a web server.

    We may use third-party web analytics services on our websites and mobile apps, such as those of Google Analytics, etc. The analytics providers that administer these services use technologies such as cookies and web beacons to help us analyze how visitors use our websites and apps.

    We, our service providers and our partners may also collect information about your activities on our websites and apps for use in providing you with content and advertising tailored to your individual interests. The information collected for these purposes may include details about things like the particular pages or advertisements you view on our websites and the actions you take on our websites and apps. Please see the “Your Rights and Choices” section of this Global Privacy Notice to learn about your ability, at any time, to opt out or limit the use of your browsing behavior for online behavioral advertising purposes.

    How We Use Personal Information We Collect

    • We may use the personal information we obtain about you to:
    • Process your transactions
  • Protect against and prevent fraud, unauthorized transactions, claims and other liabilities, and manage risk exposure with respect to the integrity and security of our network
  • Create and manage any accounts you may have with us and respond to your inquiries
  • Provide, administer and communicate with you about products, services, offers,

    programs and promotions of Vartopia, its customers, and partners (including contests,

    spiff programs and any other marketing activities)

  • Publish business directories (which may include business contact information)
  • Operate, evaluate and improve our business (including developing new products and

    services; managing our communications; determining the effectiveness of and optimizing our advertising; analyzing our products, services, websites, mobile applications and any other digital assets; facilitating the functionality of our websites, mobile applications and any other digital assets; and performing accounting, auditing, billing, reconciliation and collection activities)

  • Anonymizing personal information and preparing and furnishing aggregated data reports showing anonymized information, (including, but not limited to, the following: compilations, analyses, analytical and predictive models and rules, and other aggregated reports) for the purpose of advising our customers and partners regarding past and potential future patterns and other insights that may be extracted from this data
  • Enforce our Terms of Use or other legal rights
  • As may be required by applicable laws and regulations or requested by any judicial

    process or governmental agency having or claiming jurisdiction over Vartopia or

    Vartopia’s affiliate

  • Comply with industry standards and our policies

    We also may use the information in other ways for which we provide specific notice at the time of collection.

    Personal Information We Share

    We do not sell or otherwise disclose personal information we collect about you, except as described in this Global Privacy Notice or as we disclose to you at the time the data is collected.

    We may share personal information we collect with our affiliates, customers, and partners. We share personal information to process transactions and perform other activities that you request.

    In addition, we may share personal information with other third parties with your consent. When Vartopia acts as a service provider for third parties we may provide them with personal information we collected on their behalf.

We also may share the information with our service providers who perform services on our behalf. We authorize these service providers to use or disclose the information only as necessary to perform services on our behalf or comply with legal requirements. We require these service providers by contract to safeguard the privacy and security of personal information they process on our behalf.

On our websites, you may choose to use certain features that can be accessed through, or for which we partner with, other entities that are not otherwise affiliated with Vartopia. These features, which include social networking and geo-location tools, are operated by third parties, including social networks, and are clearly identified as such. These third parties may use or share personal information in accordance with their own privacy policies. We strongly suggest you review the third parties’ privacy policies if you use the relevant features.

We may disclose information about you (i) if we are required to do so by law or legal process, (ii) when we believe disclosure is necessary to prevent harm or financial loss, or (iii) in connection with an investigation of suspected or actual fraudulent or illegal activity.

We reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with our Global Privacy Notice. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.

Your Rights and Choices

You have certain rights regarding the personal information we maintain about you. We also offer you certain choices about what personal information we collect from you, how we use that information, and how we communicate with you.

You can choose not to provide personal information to Vartopia by refraining from conducting transactions. You also may refrain from submitting information directly to us. However, if you do not provide personal information when requested, you may not be able to benefit from the full range of Vartopia products and services, and we may not be able to provide you with information about products, services and promotions.

You can opt out of the collection and use of certain information, which we collect about you by automated means, when you visit our websites. In certain jurisdictions, you can exercise your choice via the Cookie Consent tool displayed on the bottom of Vartopia websites. Your browser

may tell you how to be notified and opt out of receiving certain types of cookies. In addition, on certain Vartopia websites, we may provide you with other choices regarding the use of cookies. Please note, however, that without cookies you may not be able to use all of the features of our websites or online services.

You can opt out of certain uses of information, which we collect about you by automated means, when you visit third-party websites and interact with our ads. We may use service providers to serve ads on those third-party websites. These ads may be customized and served based on the use of data we (and our partners) have collected on our websites and apps. In addition, some of our service providers and partners may collect information about your online activities over time and across third-party websites to customize and serve these ads. Vartopia advertisements are sometimes delivered with icons that help consumers (i) learn more about how their data is being used and (ii) exercise choices they may have regarding the use of their data. Please click where applicable, on the icon in our targeted advertisements to learn about your ability to opt out or limit the use of your browsing behavior for online behavioral advertising purposes.

You can at any time tell us not to send you marketing communications by e-mail by clicking on the unsubscribe link within the marketing e-mails you receive from us or by contacting us as indicated below. You also may opt out of receiving marketing e-mails from Vartopia by clicking here.

If your employer provides your personal information to Vartopia, you may have certain choices with respect to Vartopia’s use or disclosure of the information. Please contact your employer to learn about and to exercise your choices.

To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your personal information. We will apply your preferences going forward. In some circumstances, withdrawing your consent to Vartopia’s use or disclosure of your personal information will mean that you cannot take advantage of certain Vartopia products or services.

Subject to applicable law, you may have the right to: obtain confirmation that we hold personal information about you, request access to and receive information about the personal information we maintain about you, receive copies of the personal information we maintain about you, update and correct inaccuracies in your personal information, object to the processing of your personal information, and have the information blocked, anonymized or deleted, as appropriate. The right to access personal information may be limited in some

circumstances by local law requirements. To exercise these rights, please contact us as set forth below.

To update your preferences, ask us to remove your information from our mailing lists or submit a request to access, update, correct or delete your personal information, please contact us as specified below.

If we fall short of your expectations in processing your personal information or you wish to make a complaint about our privacy practices, please tell us because it gives us an opportunity to fix the problem. You may contact us by using the contact details provided in the “How To Contact Us” section below. To assist us in responding to your request, please give full details of the issue. We attempt to review and respond to all complaints within a reasonable time.

If you provide us with any information or material relating to another individual, you should make sure that the sharing with us and our further use as described to you from time to time is in line with applicable laws, so for example you should duly inform that individual on the processing of her/his personal data and obtain her/his consent, as may be necessary under applicable laws.

International Data Transfers

We may transfer the personal information we collect about you to recipients in countries other than the country in which the information was originally collected, including the United States of America. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Global Privacy Notice or as otherwise disclosed to you at the time the data is collected (e.g., via program specific privacy notice).

Vartopia is a global business. To offer our services, we may need to transfer your personal information among several countries, including the United States, where we are headquartered. We comply with applicable legal requirements providing adequate safeguards for the transfer of personal information to countries outside of the European Economic Area (“EEA”), United Kingdom, or Switzerland.

How We Hold and Protect Personal Information

The security of your personal information is important to Vartopia. We are committed to protecting the information we collect. We follow generally accepted industry standards (including but not limited to Secure Servers, Firewalls, Encryption and more) to protect the personal information submitted to us, both during transmission and once it is received. Of

course, there is no such thing as perfect security on the Internet. You are responsible for maintaining the secrecy of your passwords or any account information. Please be careful and responsible whenever you are online. If you have any questions about the security of your personal information, you can contact Us at the contact information below.

Data Retention

Vartopia stores personal information only for as long as it is necessary for the fulfillment of the purpose for which the personal information was collected, unless otherwise required or authorized by applicable law. We take measures to destroy or permanently de-identify personal information if required by law.

Links to Other Websites

Our websites may provide links to other websites for your convenience and information. These websites may operate independently from Vartopia. Linked websites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not owned or controlled by Vartopia, we are not responsible for the websites’ content, any use of the websites, or the privacy practices of the websites.

Updates to Our Global Privacy Notice

This Global Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on relevant websites to notify you of any significant changes to our Global Privacy Notice and indicate at the top of the Notice when it was most recently updated. If we update our Global Privacy Notice, in certain circumstances, we may seek your consent. To view the current version of the Vartopia Global Privacy Policy click here.

Compliance & Governance

Eu-US – Swiss-US Privacy Shield

Vartopia complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland to the United States in reliance on Privacy Shield. Vartopia has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit:

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

Pursuant to the Privacy Shield Frameworks, 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. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, 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 Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Vartopia remains responsible and liable under the Privacy Shield 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 Privacy Shield 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 Privacy Shield. European Union, United Kingdom, and Swiss individuals with Privacy Shield inquiries or complaints should first contact Vartopia by email

at [email protected]


has further committed to refer unresolved privacy complaints under the Privacy Shield

Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you

do not receive timely acknowledgment of your complaint, or if your complaint is not

satisfactorily addressed, please visit for

more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield 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 Privacy Shield Annex 1 at:

How to Contact Us

In compliance with the Privacy Shield 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 Privacy Shield 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:

o Global Privacy Officer

Vartopia, LLC
970 West Broadway Jackson, WY 83001 USA