VANDOO PRIVACY POLICY

INTRODUCTION

This Privacy Policy (“Policy”) is intended to be a global enterprise wide Privacy Policy applicable to all data collection by VANDOO International LLC and shall apply to your use of this website, your downloading and use of our mobile applications, your use of any affiliated third party websites that may contain a link to this Privacy Policy, or to any pages, facilities, services, or capabilities accessible on or by any top-level VANDOO domain owned by us (each, a “Site” and collectively the "Sites").   The terms “VANDOO,” “we,” “Company,” “us” or “our” refer to VANDOO International, LLC, its affiliates and/or subsidiaries. The words “you,” “your,” “yours,” “user” and “customer” refer to the individual or entity that uses our Site or submits information to our Company. Our Privacy Policy explains: (1) what information we collect and why we collect it; (2) how we use that information; (3) the choices we offer, including how to access and update your information. Specifically, our Privacy Policy covers the following topics:

Terms and Conditions

When this Privacy Policy Applies

Information We Collect

How We Use Information We Collect

Our Legal Basis for Collecting Personal Data

Your Choices and Accessing, Updating or Deleting Your Personal Data

Information You Share

Information We Share

Your Failure to Provide Personal Data

Our Retention of Your Personal Data

International Transfer

Information Security

Our Opt-in/Out-out Policy

Third Party Links

International Transfer

Information Security

Children

California Residents

Changes

Contact Us

Please familiarize yourself with our privacy practices and contact us  if you have any questions. By using the Sites, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Sites. Irrespective of which country you live in, you authorize us to transfer, store, and use your information in the United States, and any other country where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live. Learn more about our data transfer operations in the “International Transfer” section below. If you do not agree to the transfer, storage and use of your information in the United States, and any other country where we operate, please do not use the Sites or Services. Terms and Conditions By accessing or using the Sites in any manner, you also agree to be bound by VANDOO’s Terms and Conditions (the “Agreement”). Please read the Agreement carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Sites.

WHEN THIS PRIVACY POLICY APPLIES

Our Privacy Policy applies to all of the services offered by VANDOO and its affiliates, and services offered on other sites, but exclude services that have separate Privacy Policies that do not incorporate this Privacy Policy. Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

INFORMATION WE COLLECT

We collect information to provide better services to all of our users.  These features include items such as order history, saved shipping and billing addresses and “save-for-later” controller configurations. We use the term “Personal Data” to refer to any information that identifies or can be used to identify you. Common examples of personal data include: full name, home address, email address, date of birth, digital identity, such as a login name or handle, information about your device, and certain metadata. “Sensitive Personal Data” refers to a smaller subset of personal data which is considered more sensitive to the individual, such as race and ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric information, physical or mental health information, medical insurance data, or sexual orientation. VANDOO does not collect or use Sensitive Personal Data and asks that you do not provide Sensitive Personal Data to us. We collect personal data in the following ways:

Information you give us: When you create an account and user ID, download a software update, contact us by phone, email or social media or participate in an online survey or contest, we may collect a variety of information, including, but not limited to:

your name

mailing address

phone number

email address

your visits and use of our Sites

referral source

length of visit

pages viewed

social media IDs

your comments and photos

browsing history

order history including items purchased

contact preferences

payment information

other personal identifiable information you may send us

Information we get from your use of our services.

Device information

We collect device-specific information such as, but not limited to, your hardware model, web browser version, operating system version, unique device identifiers, and network information including phone number. VANDOO may associate your device identifier with your VANDOO account.

Log information

When you use our services, we automatically collect and store information in service logs. This includes:

Details of how you used our service;

Internet protocol address;

Cookies that uniquely identify your browser.

Location information

When you use our services, we may collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS, and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points and cell towers.

Local storage

We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage and application data caches.

Cookies and similar technologies

We and our partners use various technologies to collect and store information when you visit one of our services, and this may include using cookies or similar technologies to identify your browser or device.

“Cookies” are small files placed on the hard drive of your computer. We use cookies to provide features and services, such as:

Allowing you to enter your account information less frequently

Remembering your preferences

Presenting information that’s targeted to your interests

Measuring the effectiveness of our Sites, services, content and advertising

Providing other services and features that are available only through the use of cookies

Shopping behavior to determine ad servicing

A “web beacon” is an electronic image placed in the code of a web page. We use web beacons to monitor the traffic patterns of users from one page to another and to improve Site performance.

We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services, that may include:

Google Analytics

Google Tag Manager

Zendesk

MailChimp

Hotjar

New Relic

Google Adwords Pixel

Google Merchant Center

Facebook Pixel

Bing Pixel

HOW WE USE INFORMATION WE COLLECT

We use information collected from cookies and other technologies, to improve your user experience and the overall quality of our services. For example, by saving your language preferences, we’ll be able to have our services appear in the language you prefer.

We may use your personal information to:

Improve your browsing experience by personalizing the Site

Send goods purchased via the Site and supply services purchased via the Site

send statements and invoices and collect payments

Send general commercial communications

Send email notifications

Provide third parties with statistical information about users of our Site

Deal with inquiries and complaints made by or about you relating to the Site

Provide your Personal Information to associated third parties for the purpose of direct marketing

We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy. Our Legal Basis for Collecting Personal Data  Whenever we collect Personal Data from you, we may do so on the following legal bases:

Your consent to such collection and use;

Out of necessity for the performance of an agreement between us and you, such as your agreement to use our services and products;

Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Data is necessary for:

Intra-company transfers for client data for administrative purposes;

Product development and enhancement, where the processing enables VANDOO to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of our customers, and to better understand how people interact with our Sites;

Communications and marketing, including processing data for direct marketing purposes, and subject to your opt-in for these purposes, and to determine the effectiveness of our promotional campaigns and advertising;

Fraud detection and prevention;

Enhancement of our cybersecurity, including improving the security of our network and information systems; and

General business operations and diligence;

Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.

YOUR CHOICES AND ACCESSING, UPDATING OR DELETING YOUR PERSONAL DATA

People have different privacy concerns. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. We also aim to provide you with access to your Personal Data. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. Subject to applicable law, you may obtain a copy of personal information we maintain about you or you may update or correct inaccuracies in that information through your VANDOO account or by contacting us.

EUROPEAN USERS’ RIGHTS WITH RESPECT TO PERSONAL DATA

Some data protection laws, including the European Union’s General Data Protection Regulation (“GDPR”), provide you with certain rights in connection with Personal Data you have shared with us. If you are resident in the European Economic Area, you may have the following rights:

The right to be informed. You are entitled to be informed of the use of your Personal Data.  This Privacy Policy provides such information to you.

The right of access. You have the right to request a copy of your Personal Data which we hold about you.

The right of correction: You have the right to request correction or changes of your Personal Data if it is found to be inaccurate or out of date.

The right to be forgotten: You have the right to request us, at any time, to delete your Personal Data from our servers and to erase your Personal Data when it is no longer necessary for us to retain such data.  Note, however, that deletion of your Personal Data will likely impact your ability to use our services.

The right to object (opt-out): You have the right to opt-out of certain uses of your Personal Data, such as direct marketing, at any time.

The right to data portability: You have the right to a “portable” copy of your Personal Data that you have submitted to us.  Generally, this means your right to request that we move, copy or transmit your Personal Data stored on our servers / IT environment to another service provider’s servers / IT environment.

The right to refuse to be subjected to automated decision making, including profiling: You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.

The right to lodge a complaint with a supervisory authority.

 You may contact us using the contact information below, and we will consider your request in accordance with applicable laws.

ACCESSING, UPDATING OR DELETING YOUR PERSONAL INFORMATION

Whenever you use our services, we aim to provide you with access to your personal information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems. You may update or correct information about yourself by emailing us at [email protected].  If you completely delete all such information, then your account may become deactivated.  We may retain an archived copy of your records as required by law, to comply with our legal obligations, to resolve disputes, to enforce our agreements or for other legitimate business purposes.

OUR OPT-IN/OPT-OUT POLICY

By providing an email address on the VANDOO Sites, you agree that we may contact you in the event of a change in this Privacy Policy, to provide you with any service related notices, or to provide you with information about our events, invitations, or related educational information. For purposes of this Privacy Policy, “opt-in” is generally defined as any affirmative action by a user to submit or receive information, as the case may be. We currently provide the following opt-out opportunities:

At any time, you can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from us to unsubscribe from the service.

At any time, you can contact us through [email protected] or the address or telephone number provided below to unsubscribe from the service and opt-out of our right per your consent under the terms of this Privacy Policy to share your Personal Data.

Notwithstanding anything else in this Privacy Policy, please note that we always reserve the right to contact you in the event of a change in this Privacy Policy, or to provide you with any service related notices. You may also set your browser to block all cookies, including cookies associated with our services, or to indicate that a cookie is being set by us. However, please remember that many of our services may not function properly if your cookies are disabled. For example, with cookies disabled, purchasing on the Site is unavailable.

INFORMATION YOU SHARE

Our services may allow you to share information with others via social media, links, email, messaging, etc. If you share information on third-party websites that we do not control, VANDOO is not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party's website. VANDOO strongly recommends that each User review the third party's terms and policies.

INFORMATION WE SHARE

We do not share personal information with companies, organizations and individuals outside of VANDOO unless one of the following circumstances applies:

With your consent. We will share personal information with companies, organizations or individuals outside of VANDOO when we have your consent to do so. We require opt-in consent for the sharing of any sensitive personal information.

For external processing. We provide personal information to our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.

PAYMENT INFORMATION: If you make a purchase from our Site, we may collect payment information from you including, but not limited to, your credit or debit card number, cardholder name, expiration date, security code and billing address. We will securely transmit this information to a third party to process your payment. Please be aware that your payments are not processed by us. Your payment is processed by a third party processor.

For legal reasons. We will share personal information with companies, organizations or individuals outside of VANDOO if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

meet any applicable law, regulation, legal process or enforceable governmental request.

enforce applicable Terms and Conditions, including investigation of potential violations.

detect, prevent, or otherwise address fraud, security or technical issues.

protect against harm to the rights, property or safety of VANDOO, our users or the public as required or permitted by law.

to the purchaser (or prospective purchaser) of any business or asset which we currently or may prospectively offer. Except as provided in this Policy, we will not provide your information to third parties.

We may share non-personally identifiable information publicly and with our partners – like advertisers or connected sites. For example, we may share information publicly to show trends about our products and services. If VANDOO is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any personal information and give affected users notice before personal information is transferred or becomes subject to a different Privacy Policy.

YOUR FAILURE TO PROVIDE PERSONAL DATA

Your provision of Personal Data is required in order to use certain parts of our services and our products.  If you fail to provide such Personal Data, you may not be able to access and use our services and/or our products, or parts of our services and/or our products. Our Retention of Your Personal DataWe may retain Personal Data for a period of time consistent with the original purpose for collection.  For example, we keep your Personal Data for no longer than reasonably necessary for your use of our products and services and for a reasonable period of time afterward. We also may retain your Personal Data during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.If you choose to close your account, we generally delete closed account information within 30 days of account closure, except as noted below. We retain your Personal Data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms and Conditions, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

INTERNATIONAL TRANSFER

We are committed to complying with applicable laws, regulations and mandatory government standards regarding the protection of Personal Data. Since we are a global organization, Personal Data and any additional information submitted may be used globally in connection with employment, business processes within VANDOO, or communicating with our clients. Therefore, Personal Data may be transferred to other VANDOO entities worldwide, where it will be processed in accordance with this Privacy Policy and laws that are applicable in each country. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country. If we transfer your Personal Data out of your jurisdiction, we will implement suitable safeguards and rely on legally-provided mechanisms to lawfully transfer data across borders to ensure that your Personal Data is protected.

INFORMATION SECURITY

We work hard to protect VANDOO and our users from unauthorized access or unauthorized alteration, disclosure or destruction of information we hold. In particular:

We encrypt many of our services using SSL.

We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to the system.

We restrict access to personal information to VANDOO employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

Data transmission over the Internet is inherently insecure. We cannot guarantee the security of any data or Personal Information sent over the Internet. You are responsible for keeping any of your account information confidential including, but not limited to, password and user details. We will not ask you for your password via email. Please take great care in protecting your account information and do not share it with anyone.

CHILDREN

The Sites and services are not intended for use by children.  We do not intentionally gather personally identifiable information about visitors who are under the age of 13.  If a child has provided us with personally identifiable information, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 13, please contact customer support.  If we learn that we have inadvertently collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible. Children under the age of 16 must have parental consent prior to accessing and using our Site. We may collect information about children including, but not limited to, name, address, contact number, email address and purchase history. The information we obtain may be used for marketing purposes, quality assurance, reporting and to provide a better experience for our customers. Children will not be required to disclose more information about themselves than necessary to use our Site. Parents must consent to our collection of Personal Information about their children. Parents may limit the amount of information obtained about their children and the extent to which their child’s information is used, stored or shared with third parties.

CALIFORNIA RESIDENTS

California residents are entitled to contact us to request information about whether we have disclosed personal information third parties for the third parties’ direct marketing purposes. Upon receipt of a request by a California customer, and as required by California state law, we will provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed. California customers may request further information about our compliance with this law by e-mailing us at the address listed above.  Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this e-mail address.

CHANGES

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services or products, email notification or Privacy Policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.