Last Modified: March 7, 2023
Vartopia, LLC and its affiliates (collectively, “Vartopia,” “we,” “us,” or “our”) respect your privacy. Please read the following to learn more about our Privacy Policy.
This Privacy Policy applies to information collected online and offline by Vartopia through your use of the Vartopia website at https://www.vartopia.com and any subdomains thereof (the “Site”) and any subdomains thereof (the “Site”) and the services, features, and information available on the Site and/or any mobile applications we may offer (together with the Site, along with associated and successor websites, applications, features, information, and services, or any part thereof, the “Services”).
By using or accessing the Site or Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.
We encourage you to read this Privacy Policy carefully when using or accessing the Site or Services, or when providing information to us through the Site. You understand that by using and/or accessing the Site or Services you are accepting our practices as described in this Privacy Policy.
You may print a copy of this Privacy Policy by clicking here Vartopia Privacy Policy 2022. If you have a disability, you may access this Privacy Policy in an alternative format by contacting [email protected].If you have any questions about this Privacy Policy or our privacy or security practices, or to report a security related concern, you may contact us at [email protected].
Privacy Policy Table of Contents
What this Privacy Policy Covers
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
Compliance & Governance
Other State Law Privacy Rights
Privacy Notice for EU 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 Service. “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 Services are available to individuals located in the European Economic Area or the United Kingdom, 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 Services, we may receive personally identifiable information about you in connection with our provision of the Services to your Organization. To the extent we process (as defined below) that personally identifiable information solely in order to provide the Services 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:
| Category of Personal Data | Examples of Personal Data We Collect | Categories of Third Parties With Whom We Share this Personal Data: |
|---|---|---|
| Profile or Contact Data |
|
|
| Device/IP Data |
|
|
| Web Analytics |
|
|
| Social Network Data |
|
|
| Professional or Employment- Related Data |
|
|
| Geolocation Data |
|
|
| Inferences Drawn From Other Personal Data Collected |
|
|
| Other Identifying Information that You Voluntarily Choose to Provide |
|
|
| [Other] |
|
Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
Our Commercial or Business Purposes for Collecting Personal Data
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.
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:
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 http://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
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 Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (General Data Protection Regulation) (“EU GDPR”) or the EU GDPR as saved into UK law by virtue of section 3 of the UK’s European Union (Withdrawal) Act 2018 (“UK GDPR”) and the UK Data Protection Act 2018 (as applicable, 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].
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: https://www.privacyshield.gov.
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. Furthermore, you have the right to demand deletion of personal data that has been handled in violation of the Privacy Shield Principles. 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].
Vartopia 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 https://bbbprograms.org/privacy-shield-complaints/ 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: https://www.privacyshield.gov/article?id=ANNEX-I-introduction/.
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:
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 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.
You may submit a Valid Request using the following methods:
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.
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.
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.
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.
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, Company is remains committed to the Principles of the EU-U.S. Privacy Shield 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 Privacy Shield.
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. Privacy Shield 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 Privacy Shield, and individuals can still file complaints with the Federal Trade Commission (FTC) and/or local supervisory authorities. The FTC can still enforce the Privacy Shield against current and former participating companies. We remain committed to our obligations under the Privacy Shield 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://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.
Hampton, New Hampshire, USA
Phoenix, Arizona, USA
Chandigarh, India
© 2023 Vartopia. All rights reserved. |Privacy Policy |Vartopia Security
