VNDLY INC.
Website Privacy Policy
Last Revised: April 1, 2021
PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THE SERVICES
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.
This Policy applies to information we collect on this Website or in emails and other electronic messages between you and this Website, and information gathered when you interact with our advertising on third-party websites if such advertisements include links to this Policy. This Policy does not apply to information collected by us offline or through any other means, including on any other website operated by VNDLY or any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the Website (for further information, see below, “Third-party Websites”).
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:
You may provide us Personal Information when you:
The information that you provide in each case will vary, and of course, you may choose not to provide VNDLY with Personally Identifying Information. In some cases, you may be able to provide Personal Information via email or free-form text fields, such as contacting VNDLY to request further information. When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data.
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:
We use the following categories of cookies on our Website.
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.
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.
Text Messaging. You may have the opportunity to receive SMS or “text” messages, pre-recorded voice messages or auto-dialed phone calls from VNDLY, its affiliates and related entities as well as third parties. Such messaging may be used to authenticate your identity or mobile device, as well as provide you informational updates about services or products you may have requested. In providing your mobile device number or cell phone number to VNDLY, you knowingly consent to such communications from VNDLY or for VNDLY to use your cell phone number or mobile device number in accordance with our Terms of Use. In providing your number, you represent that you have the authority to agree to receive text messages at the telephone number that you provide to VNDLY, or from which you sent the text message request to us. You further acknowledge that no purchase is required to opt into this service, and you may opt out at any time by following the instructions provided in our communications with you.
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:
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. We will share your Personal Information with the following third parties in order to fulfill the service that they provide to us. These third-parties are under contract to keep your Personal Information secure and not to use it for any reason other than to fulfill the service we have requested from them.
There are circumstances where VNDLY 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, VNDLY 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.
Other than as disclosed in this Policy, the Website does not track users over time and across third-party websites to provide targeted advertising. Therefore, the Website does not operate any differently when it receives Do Not Track (“DNT”) signals from your internet web browser.
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. You may exercise each of your rights as identified below, subject to our verification of your identity.
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.
For Website Visitors in the European Union (“EU”)
Under the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or “GDPR”), individuals in the EU are afforded specific rights with respect to their Personal Information, or “personal data” as defined under the GDPR. For the purposes of this Policy, VNDLY operates as a data controller. Any personal data we collect from you is processed in the United States and under the terms of this Policy.
Any personal data we collect from you is processed in the legitimate interest of our business and providing our services to you as the lawful means of such processing. You may always withdraw your consent to our use of your personal data as described below. We will only retain your personal data for the time necessary to provide you the information and services to which you have consented, to comply with the law and in accordance with your rights below.
The Data Controller is:
VNDLY, Inc.
4900 Parkway Drive, Suite 125, Mason, OH 45040
privacyeu@vndly.com
You can exercise any of the following rights, subject to verification of your identity, by notifying us as described below:
Submit Complaints or Questions. If you wish to raise a complaint on how we have handled your personal data, you can contact us as described below under “Accountability, Compliance and Contact.” If you reside in a European Union member state, you may also lodge a complaint with the supervisory authority in your country.
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.
Users Located in Australia
If you are a User who accesses our Website in Australia, this section applies to you. We are subject to the operation of the Privacy Act 1988 (“Australian Privacy Act”).
Here are the specific points you should be aware of:
We will not use or disclose Personal Information for the purpose of our direct marketing to you unless:
You may opt out of any marketing materials we send to you through an unsubscribe mechanism. If you have requested not to receive further direct marketing messages, we may continue to provide you with messages that are not regarded as “direct marketing” under the Australian Privacy Act, including changes to our terms, system alerts, and other information related to your account as permitted under the Australian Privacy Act and the Spam Act 2003 (Cth).
If you think the information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, we will take reasonable steps, consistent with our obligations under the Australian Privacy Act, to correct that information upon your request. If you find that the information we have is not up to date or is inaccurate or incomplete, please contact us in writing at privacy@vndly.com, so we can update our records. We will respond to all requests for correction within a reasonable time.
If you are unsatisfied with our response to a privacy matter, you may consult either an independent advisor or contact the Office of the Australian Information Commissioner for additional help. We will provide our full cooperation if you pursue this course of action.
Location of VNDLY’s Services
VNDLY’s Corporate headquarters is based in the State of Ohio within the United States. VNDLY provides access to their Products and Services within the United States, Australia, Canada, European Union, United Kingdom, and Mexico. Users’ acknowledge that VNDLY does not warrant or represent that this Policy, or the Products and Services use of Personal Information, complies with the laws of any other jurisdiction. Further, Users’ acknowledge that Personal Information will be obtained and processed in accordance with this Policy, irrespective of where such information may otherwise be stored.
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. If you ever feel your information has been compromised or is at risk, please notify us via the “Accountability, Compliance and Contact” information section below.
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.
Accessing Your Personally Identifying Information Once Given
If you believe your Personally Identifying Information is inaccurate, you may contact VNDLY to amend or delete your Personally Identifying Information. You have the right to request information about the existence, use, and disclosure of your Personally Identifying Information and to challenge the accuracy and completeness of your Personally Identifying Information, and to have your Personally Identifying Information amended where inaccurate or deleted from VNDLY’s database. To do so, simply e-mail VNDLY at the e-mail address set forth in this Privacy Policy.
Third-Party Websites
On occasion, the Website 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 does not endorse these websites and 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. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. 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
VNDLY takes our responsibility to protect your information very seriously. VNDLY reassures our compliance with this Privacy Policy and applicable legal standards to keep your information secure. For additional questions or inquiries, please direct in the following manner:
Located in the United States, Australia, Canada, and Mexico. All questions and inquiries can be directed to a VNDLY representative at privacy@vndly.com.
Located within the European Union. All questions and inquiries can be directed to our EU representative at privacyeu@vndly.com.
Located within the United Kingdom. All questions and inquiries can be directed to our UK representative at privacyuk@vndly.com.
