Privacy
THIS IS A WEBSITE PRIVACY DRAFTED UNDER U.S. LAW. THIS POLICY IS NOT INTENDED TO SATISFY ANY ‘FAIR PROCESSING NOTICE’ OBLIGATIONS THAT YOU MAY HAVE UNDER GDPR OR OTHER APPLICABLE NON-US LAW.
VENGO INC. Privacy Policy
EFFECTIVE DATE: July 10, 2020
In this Privacy Policy (“Policy”), we describe how Vengo Inc. (“Vengo”) collects, uses, and discloses information that we obtain about visitors to our website Vengolabs.com (the “Site”) and the services available through our Site and Kiosks (collectively, the “Services”).
By visiting the Site, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. The Vengo Terms of Service are incorporated by reference into this Policy.
The Information We Collect About You
We collect information about you directly from you and from third parties, and automatically through your use of our Site or Services.
Information We Collect Directly From You On Our Site.
The information we collect from you depends on how you use our Site.
- Online contact forms. If you use our website and wish to contact us by using our contact forms, we collect preliminary information about the nature of your contacting us (e.g., whether you are contacting us as a media agency, property owner, vendor, customer, vending operator, potential employee, or potential branding partner). Depending on your reason for contacting us, we may collect your first and last name, your job title, your email address, your phone number, your company, your website, and other
- To subscribe to our newsletter.To subscribe to our newsletter. If you use our Site to subscribe to our newsletter, we will collect your email address.
- To make a purchase.To make a purchase. Our goods and services are not sold through our Site. As such, we do not collect, disclose or process any other personal information or payment information related to sales of our Services to you through our Site or applications.
Information We Collect Directly From You On Our Kiosks.
The information we collect from you depends on how you use our Kiosks.
- To make a purchase. If you use our Kiosks to make a purchase, we use payment card processor to collect, store and process your payment information.
- To receive a product sample or special offerYou may, but are not required to use our Kiosks to receive a product sample or other special offer through our brand network, we may collect your name, email address, mobile phone numbers, and, depending on the nature of the offer, your age, date of birth, or year of birth. You may also be prompted to answer survey questions which will vary depending on the brand partner.
Information We Collect Automatically.
We automatically collect information about your use of our Site through cookies, web beacons, and other technologies. The information we collect includes:
- your operating system;
- web pages you view on the Site; links you click on the Site;
- the length of time you visit our Site and or use our Services;
We maintain this information in the aggregate and do not combine this information with other personal information we collect about you. Please see the section “Our Use of Cookies and Other Tracking Mechanisms” below for more information
How We May Use Your Information
We may use your information, including your personal information, for the following purposes:
- To provide our Services to you.
- To vend products and to connect you with our branding partners for special offers and sample products.
- To contact you in order to verify your contact information
- To facilitate our affiliates’ and branding partners’ verification of your contact information.
- To communicate with you about your use of our Services, to respond to your inquiries, and for other customer service purposes.
- To send you email marketing about our products and services.
- To send you news and newsletters.
- To send you email marketing about products and services of our affiliated entities.
- To send you email marketing about products and services of other entities that we think may be of interest to you.
- To assist us in advertising on third-party websites, mobile apps, and other online services, and to evaluate the success of our adverting campaigns through third-party channels (including our online targeted advertising and offline promotional campaigns).
- To better understand how users access and use our Services, both on an aggregated and individualized basis. For example, we will evaluate which features of our Site and Kiosks are most (or least) used by users, and we will use this information.
- For research and analytics purposes
- To administer surveys and questionnaires, such as for market research or member satisfaction purposes.
- To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
- Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Service or this Privacy Policy.
How We Share Your Information
We may share your information, including personal information, as follows:
- Service Providers. We disclose the information we collect from you to service providers, contractors or agents who perform functions on our behalf. These service providers include marketing and advertising services, payment and chargeback processors, and information verification services.
- Brand Partners. We share your personal information with brand partners when you use our Kiosks to opt-in to one of their promotional campaigns.
- Affiliates. We disclose the information we collect from you to our affiliates or subsidiaries.
We also disclose information in the following circumstances:
- Business Transfers.Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third-party advisors, including attorneys and consultants.
- In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
- To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.
- Aggregate and De-Identified Information. We share aggregate, anonymized, or de-identified information about users with our affiliates and other service providers for marketing, advertising, research or similar purposes.
Our Use of Cookies and Other Tracking Mechanisms
We and our service providers use cookies and other tracking mechanisms to track information about your use of our Site or Services. We may combine this information with other personal information we collect from you (and our service providers may do so on our behalf).
Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.
- Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site and Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site and Services.
- Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.
Third-Party Analytics.
We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site. We also may use other analytic means to evaluate our Site. We use these tools to help us improve our Site’s performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
Third-Party Links
Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
Security of My Personal Information
We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.
What Choices Do I Have Regarding Use of My Personal Information?
We may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.
Children Under 13
Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.
Contact Us
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at privacy@vengolabs.com.
Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.
ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
Last Updated: July 10, 2020
Your Rights under the California Consumer Privacy Act (CCPA). If you are a California resident, with some exceptions under California law, you have the right to:
- be free from discriminatory treatment for your exercise of the privacy rights conferred by the CCPA,
- request the deletion of your personal information,
- opt-out of the sale of your personal information (if any) email: privacy@vengolabs.com and
- request that we disclose information about our collection and use of your personal information over the past 12 months including:
- the specific pieces and categories of personal information we collected,
- the categories of sources of the personal information we collected about you,
- our business purpose for collecting or selling (if any) the personal information, and
- for each category of personal information, the categories of third parties to whom the personal information was disclosed or sold.
In order to verify your request and protect your privacy, we may need you to supply additional information.
Instructions. You or your authorized agent can submit your request by going to our calling us at (866)-526-7054 (toll free) or by emailing us at privacy@vengolabs.com. In general, we will verify your request and your identity when you provide us with your name along with either your email or phone number so that we may match it to information that we maintain about you. We may also attempt to verify your request and identity through our third-party identity verification service. Authorized agents will be required to submit additional verification that they are in fact authorized by you to make a deletion request or request for disclosure of information.
If you have questions or concerns about our privacy practices, you may contact us at privacy@vengolabs.com.
Categories of Personal Information that We Collect, Disclose, and Sell
The following chart describes what categories of personal information we have collected over the past 12 months, whether we disclosed that information for a business purpose, whether we sold that information, and the categories of third parties to whom we sold or disclosed that information. We do not sell the personal information of minors under 16 years of age with actual knowledge that they are under 16 years of age:
CCPA Categories of Personal Information We Have Collected
Have We collected?
Categories of Third Party to whom this information is disclosed for a business purpose
Categories of Third Party to whom this information is sold
Identifiers: Real name, alias, postal address, online identifier, Internet Protocol (IP) address, email address.
Yes
Marketing and
advertising services
Payment and
chargeback processors
Address verification
Service
Payment processors
Marketing partners
Customer Records: Paper and electronic customer records containing personal information, such as name of our customer.
Yes
Marketing and
advertising services
Payment and
chargeback processors
Address verification
Service
Payment processors
Marketing partners
Protected Classifications: Characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, ancestry, marital status, sexual orientation, political activities and affiliates, military or veteran status, status as a victim of domestic violence, assault or stalking, disability, citizenship status, and genetic information.
Yes
Age gate for campaigns
N/A
Usage Data: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement.
No
N/A
N/A
Geolocation Data: Precise geographic location information about a particular individual or device.
No
N/A
N/A
Profiles and Inferences: Inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
No
N/A
N/A
Your Privacy Rights under California’s Shine-the-Light Law (Cal. Civ. Code § 1798.83)
California residents may request a list of certain third parties to which we have disclosed personally identifiable information about you for their own direct marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting us at privacy@vengolabs.com. Please allow up to thirty (30) days for a response.
