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VNDLY, INC.

Website Privacy Policy

Last Revised: February 13, 2020

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THE WEBSITE

VNDLY, Inc. (“VNDLY,” “we,” “us,” or “our”), recognizes the importance of your privacy. This Privacy Policy outlines the types of Personally Identifying Information we gather when you use our website at: www.vndly.com as well as any website made available by VNDLY with this Privacy Policy (collectively, the “Website”) and how we use that information. It is important to review this Privacy Policy in its entirety and it should be read in conjunction with our Website Terms of Use, into which this Policy is incorporated by reference.

As part of the operation of the Website, certain pieces of information are gathered about the users (individually, “you” or a “User” and collectively, “Users”). This Privacy Policy contains explanations regarding the types of information collected, what is done with such information, and how to correct or change the information. By using our Website, you agree to the terms of this Policy. This Policy may change from time to time (see below, “Changes to this Policy”). Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

The Information We Collect

Information You Provide to VNDLY

We collect Personally Identifying Information that you provide to VNDLY. “Personally Identifying Information” is information that individually identifies you, such as your:

  • First and last name;
  • physical address;
  • phone number;
  • e-mail address;
  • comments or messages provided in free text boxes; and
  • any other information that would allow someone to identify or contact you.

You may provide us Personal Information when you:

  • request information;
  • schedule a demonstration;
  • submit an employment application; or
  • subscribe to our emails.

The information that you provide in each case will vary, and of course, you may choose not to provide VNDLY with Personally Identifying Information.

Information We Collect Automatically When You Use the Website

When you access or use the Website, we may automatically collect information about you using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Website. Some of the tools we use to automatically collect information about you may include:

  1. Cookies. A “cookie” is a small data file transmitted from a website to your device’s hard drive. Cookies are usually defined in one of two ways, and we may use both of them:
    1. session cookies, which do not stay on your device after you close your browser, and
    2. persistent cookies, which remain on your device until you delete them or they expire.

    We use the following categories of cookies on our Website.
    1. Strictly Necessary Cookies.These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have requested, such as maintaining a record of your purchased items (e.g. a shopping cart), cannot be provided.
    2. Performance Cookies. These cookies collect anonymous information on how people use our Website to help us understand how you arrive at our site, browse or use our Website and highlight areas where we can improve, such as navigation. The data stored by these cookies never shows personal details from which your individual identity can be established.
    3. Functionality Cookies. These cookies remember choices you make such as the country from which you visit our Website, your preferred language, and your search parameters. This information can then be used to provide you with an experience more appropriate to your selections and to make your visits to our Website more tailored to your preferences. The information in these cookies may be anonymized. These cookies cannot track your browsing activity on other websites.
    4. Targeting Cookies or Advertising Cookies. These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third-party advertising networks.
      One such trusted third-party partner is Google Analytics. The Website sends aggregated, non-Personal Information to Google Analytics for the purpose of providing us with the ability to conduct technical and statistical analysis on the Website’s performance. For more information on how Google Analytics supports the Website and uses information sent from the Website, please review Google’s privacy policy available at https://policies.google.com/technologies/partner-sites.

    Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. However, by disabling cookies on your device, you may be prohibited from full use of the Website’s features or lose access to some functionality.

  2. Web Beacons. A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior. If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of our third-party marketing partners may use Web Beacons to track your interaction with online advertising banners on our Website. This information is only collected in aggregate form and will not be linked to your Personal Information. Please note that any image file on a webpage can act as a Web Beacon.
  3. Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. The tracking is accomplished through a redirection system. The redirection system allows us to understand how the link is being used by email recipients. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.
  4. Third-party Websites and Services. We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered on our Website and also on the websites where our marketing communications are appearing. For example, we may collect data where our banner advertisements are displayed on third-party websites.
  5. Social Media Features and Widgets. The Website includes social media features and widgets. These features may collect your IP address, which page you are visiting through the Website, other information, and may set a cookie to enable the feature to function properly. Social media functions are either hosted by a third party or hosted directly through the Website. Your interactions with these features are governed by the privacy policy of the company providing them.

Your Choices and Selecting Your Privacy Preferences

We want to provide you with relevant information that you have requested.

If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed. Any transactional or service-oriented messages are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

We will not intentionally send you email newsletters and marketing emails unless you consent to receive such marketing information. After you request to receive these emails, you may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.

Any such communications you receive from us will be administered in accordance with your preferences and this Policy.In addition, under the Privacy Shield Principles, you have the right to opt out of uses of your personal information or disclosures of your personal information to third parties. You may submit an opt-out request via email to privacy@vndly.com.

Using the Information

Use in General. We may use your information for a variety of purposes, including to:

  • Provide, operate, maintain and improve the Website;
  • Respond to your comments, questions, and requests and to provide customer service and support;
  • Prevent potentially illegal activities;
  • Fulfill your requests;
  • Provide information that is relevant to you;
  • Monitor and analyze trends, usage, and activities in connection with the Website and for marketing or advertising purposes; and
  • For other purposes about which we notify you.
  • Use of Aggregate or De-Identified Information. In addition to the individual data use described in this Privacy Policy, we may aggregate information about you and other individual users together, or otherwise de-identify the information about you, so that the information does not identify you personally. We may use information in these forms for a variety of purposes, including for research and analysis, administration of the Website, and advertising.

Sharing and Disclosure of Information

We will not share Personally Identifying Information about you with any third parties except as described in this Privacy Policy:

  • Service Providers. We may share your Personally Identifying Information with third-party vendors, contractors, and other service providers working on behalf of VNDLY and require access to your Personally Identifying Information to carry out that work.
  • Compliance with Laws. We may disclose your Personally Identifying Information to a third party if (1) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (2) to enforce our agreements, policies, or Terms of Use, or (3) to respond to an emergency which we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person.
  • Affiliates. We may share information we have collected under this Privacy Policy with affiliates of VNDLY for use as otherwise described in this Privacy Policy.

There are circumstances where Company may decide to buy, sell, or reorganize its business in selected countries. Under these circumstances, it may be necessary to share or receive Personal Information with prospective or actual partners or affiliates. In such circumstances, Company will ensure your information is used in accordance with this Policy.

Your California Rights

Pursuant to California Civil Code Section § 1798.83, we will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.

If you are a California consumer as defined by the California Consumer Privacy Act of 2018, you may be afforded additional rights with respect to your “Personal Information” as that term is explicitly defined under California law. Any Personal Information we collect is collected for the commercial purpose of effectively operating the Website, communicating with you, as well as enabling you to learn more about, and benefit from, our services.

Access: You may email us at privacy@vndly.com to request a copy of the Personal Information our Website databases currently contain.

Prohibit Data Sharing. When applicable, you may prohibit the sharing of your Personal Information by submitting a request via email to privacy@vndly.com. In your email, please explain how you wish us to prohibit the sharing of your personal data, and which categories of third parties you want to prohibit from receiving your Personal Information. When such prohibitions are not possible to provide our services to you, we will advise you accordingly. You can then choose to exercise any other rights under this Policy.

Portability. Upon request and when possible, we can provide you with copies of your Personal Information. You may submit a request via email to privacy@vndly.com. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy.

Deletion. If you should wish to cease use of our Website and have your Personal Information deleted from our Website, then you may submit a request by emailing us at privacy@vndly.com. Upon receipt of such a request for deletion, we will confirm receipt and will confirm once your Personal Information has been deleted. Where applicable, we will ensure such changes are shared with trusted third parties.

We do not sell your Personal Information. If we ever decide to sell Personal Information, we will provide you notice and update this Privacy Policy. In addition, we will post a link entitled “Do Not Sell My Personal Information” by which you can opt out of any such selling of your Personal Information.

In addition, if a California resident exercises his or her rights under California law, including the CCPA, we shall not discriminate against that California resident by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action.

EU-U.S. Privacy Shield Framework

VNDLY participates in and complies with the EU-U.S. Privacy Shield Framework and 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. VNDLY has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. VNDLY is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit the Department of Commerce’s Privacy Shield website.

Please direct any inquiries or complaints regarding our compliance with the Principles to privacy@vndly.com. If VNDLY does not resolve your complaint, you may submit your complaint free of charge for resolution to JAMS, VNDLY’s designated independent Privacy Shield dispute resolution provider. Under certain conditions specified by the Principles, you may also be able to invoke binding arbitration to resolve your complaint. If VNDLY shares EU Data with a third-party service provider that processes the data solely on VNDLY’s behalf, then VNDLY may be held liable for that third party’s processing of EU Data in violation of the Principles, unless VNDLY can prove that it is not responsible for the event giving rise to the damage.

Safeguards

VNDLY protects your Personally Identifying Information by using safeguards that it has determined are appropriate to the sensitivity of the information. Unfortunately, neither VNDLY’s network nor data transmission over the Internet can be guaranteed to be 100% secure.

Accuracy

You have the right to update, modify, amend, or correct errors in your Personally Identifying Information by contacting VNDLY. We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and processing.

Online Tracking

The Website does not respond to Do Not Track signals. Third parties cannot collect Personally Identifying Information about you when you use the Website.

Third-Party Websites:

On occasion, the Website is provides “hyperlinks” to third-party websites. For example, VNDLY contracts with a third party to host its open employment positions and process any applications for those positions. Please note that VNDLY is not responsible in any way for the privacy practices of other websites and recommends you review the privacy policies of those other companies’ websites before using them.

Minors

The Website is not intended for people under the age of 18. Further, we do not knowingly collect Personally Identifying Information from children under the age of 18. If you are a parent or guardian of a child under the age of 18 and believe he or she has disclosed Personally Identifying Information to us, please contact us at the e-mail address set forth in this Privacy Policy and VNDLY will delete such Personally Identifying Information.

Changes to This Policy

Please note this Privacy Policy is subject to change from time to time. We will notify you of material changes to this Privacy Policy by either sending you an e-mail or by including prominent notice of such change the Website, such as a date change in the “Last Revised” block above. The effective date of each version of the Privacy Policy will be included in this Privacy Policy. Prior versions of this Privacy Policy will be kept in an archive for you to view for a reasonable period of time.

Accountability, Compliance and Contact

We take your privacy seriously. You may address any question regarding VNDLY’s compliance with this Privacy Policy by contacting VNDLY at: privacy@vndly.com