VONTÉLLE LLC PRIVACY & SECURITY POLICY
This Privacy & Security Policy (the “Policy”) describes how VONTÉLLE LLC (VONTÉLLE LLC, “we,” “our,” or “us”) will collect, use, and disclose information. This Policy applies to our website and any services that link to this Policy. This Policy describes how we collect, use, and share information about you in the course of providing our services and explains your rights with regards to that information. This Policy applies to our web site and associated mobile applications (“Site”). This Policy does not apply to your protected health information, which is governed by the Health Insurance Portability and Accountability Act of 1996 Notice (“HIPAA”).
HOW WE COLLECT THE INFORMATION
When using our website at (the “Site”) or our services, you may provide us with your personal information through a variety of methods, including the following: (1) via signups on our Site, such as through the creation of an account; (2) from an online or email purchase; (3) when you enter a sweepstakes, giveaway, contest, or other promotion, or complete a survey; (4) upon contacting us, such as through customer service communications, including our online chat features; (5) upon signing up at an event; (6) upon registering a VONTÉLLE LLC. product; (7) when you submit a business reply, product, or claim; (8) when you post material to the Site, such as through product reviews; or (9) when you interact with us for any other purpose. Information that you provide through the Site can be combined with information that we collect from you in any other way.
We may also automatically collect information (including but not limited to your Internet Protocol address) when you use and/or visit the Site to improve our products and communications, by observing your actions on our Site using cookies.
We may also receive information about you from third parties to use for marketing analytics and combine it with the information you have provided to us.
Any and all use of any information collected by us via any of the above-referenced methods will be governed by this Policy.
THE INFORMATION WE COLLECT
When you interact with us, we may collect information that you choose to provide, such as your name, postal address, email address, phone number, payment information (including credit or debit card numbers) and other financial information, transaction and purchasing history, demographic information (such as your age, income level marital status, and gender), your generalized location information, date of birth, information regarding your membership with other organizations (e.g., to provide discounts), medical information and health insurance information, prescription information, photos and recordings, and any other information you provide when you communicate with us and/or use our Site, such as preferences, characteristics and trends.
If you contact our customer service department, you may need to provide us with additional information so that we can respond to your questions or concerns as completely and thoroughly as possible. If you create an account with us, we collect your username and password. If you are providing delivery information or other information which is not your own, then you must have that person’s permission to give us their information and for us to use and share it for the purposes specified.
When you make a purchase, we will collect your payment card, gift card, or other payment information. VONTÉLLE LLC. takes reasonable steps to protect the security of payment card information.
Some of this information covered by this Policy may be subject to the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) policies on the collection of information that is considered “protected health information” (“PHI”). When the information that we collect is considered PHI, we will handle that information in accordance with this Policy.
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THE INFORMATION WE DO NOT COLLECT
We do not collect biometric information, sensory information, professional or employment-related information or non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232(g), 34 C.F.R. Part 99).
HOW DO WE USE THIS INFORMATION
We may use the information we collect for any lawful purpose, including the following:
1) To process and fulfill your order, requests, transactions and payments, including sending you emails to confirm your order status and shipment, and to provide other related communications, such as to confirm your order and to prevent fraud.
2) To administer a contest, promotion, survey, or other Site feature(s), and to provide you with the relevant products or services (for instance to deliver a prize you may have won in a contest).
3) To send you information/materials via email or mail about products, offers, and news we think could interest you. This information may relate to products, services, offers, and news of VONTÉLLE LLC. products or other products and services.
4) To operate and improve the Site, including to analyze visits to the Site and learn about our visitors so we can operate the Site and improve our products and services and deliver the best user experience.
5) To communicate with you, including responding to your inquiries and to provide you with support.
6) To comply with the law and to maintain the security of our Site.
7) As otherwise disclosed at the time of collection or use.
8) For other business purposes, as provided in this Policy, including all future amendments to this Policy.
9) To improve our product offerings, services and marketing communications and personalize your website experience and to deliver content and products and service offerings relevant to your interests, including targeted offers and ads throughout our Site, third-party sites and via email or text messaging (with your consent, as you hereby acknowledge, where and when required by law).
10) To provide, support, personalize, and develop our Site, products, and services.
11) To create, maintain, customize, and secure your account with us and to maintain the safety, security and integrity of our Site, products, services, databases and other technology assets.
12) For testing, research, analysis, and product development, including to develop and improve our Site, products, and services.
13) To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
14) As described to you when collecting your personal information; or
15) To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred.
When you make a purchase, you can choose to save your information to obtain a faster checkout for purchases and/or you can choose to receive emails, which provide you with information regarding our other products and services.
SHARING INFORMATION WITH THIRD PARTIES
We engage service providers to perform services in connection with the operation of our business. We may share personal information with service providers so that they can perform these services. Examples of these services include payment processing and authorization, fraud protection and credit risk reduction, product customization, order fulfillment and shipping, marketing and promotional material distribution, website evaluation, data analysis and, where applicable, data cleansing.
In proceeding with your online order, you agree that any information associated with the order, such as the delivery name and address (if different from yours), will be processed using service providers.
Personal information collected through our Site may be shared between us and these service providers. We also share personal information with selected third parties for their own marketing purposes.
We may release personal information if we believe in good faith that: (1) the law or legal process requires it; (2) we have received a valid administrative request from a law enforcement agency; or (3) such release is necessary or appropriate (in our sole discretion) to protect the rights, property, or safety of VONTÉLLE LLC., or any of our service providers, customers, or others.
We may also share your information with your consent or as otherwise disclosed at the time of data collection or sharing.
As with any business, it is possible that as our business develops, we might go through a business transition, such as a merger, acquisition by another company, or the sale of all or a portion of our assets, or buying online stores or other assets, including at bankruptcy. In such transactions, information about customers will likely be transferred.
The Site may allow you to provide comments in various sections of our Site, such as in product reviews. Please be aware that the information you post in these areas may be available to visitors of the Site and to the general public.
We share aggregated and de-identified information, or any other technical information, without limitation. For example, we may share aggregated demographic information about the Site visitors with our service providers or vendors, so that they can provide marketing analysis and consult on advertising strategies. We also may share technical information, such as the number of users who visited the Site during a specific time period or who purchased a specific product through the Site, with our marketing service providers, advertisers, and others from time to time. This information generally is shared in an aggregated form.
DIGITAL ADVERTISING & ANALYTICS
We may work with service providers that collect data about your use of the Site over time for non-advertising purposes subject to their privacy policies. We use analytics providers such as Google Analytics to gather and analyze aggregated anonymous user information. For more information about Google Analytics, please visit You can opt out of Google’s collection and processing of data generated by your use of the Site by going to .
THIRD-PARTY LINKS & PLUG-IN
The Site may provide links to third-party website or apps, including our social media pages. We do not control the privacy practices of those website or apps, and they are not covered by this Policy. You should review the privacy policies of these other website or apps that you use to learn about their data practices.
The Site may also include integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share information or you otherwise interact with social media features on the Site, those social media companies may collect information about you and may use and share such information in accordance with their own policies, including by sharing such information with us or the general public. Your interactions with third-party social media companies and the use of their features are governed by the privacy policies of the companies that provide those features. We encourage you to read the privacy policies for any social media accounts you create and use.
CALIFORNIA CONSUMER PRIVACY RIGHTS
Your Rights and Choices
The California Consumer Privacy Act of 2018 (“CCPA”), and other California privacy laws, provide California consumers specific rights concerning their personal information, including, the right to request that we disclose what personal information we collect, use, disclose, and sell. This section describes your rights and how you may exercise those rights as well as describes how we, VONTÉLLE LLC. handle your personal information. If you choose to exercise these rights, we will not discriminate against you because of it.
You or your authorized agent can request: 1) a disclosure of your personal information we collect, use, disclose, or sell; 2) to delete your personal information we collect, or maintain; and 3) to opt-out of the sale of your personal information. If you choose to submit a request through an authorized agent, we will require proof that the authorized agent has your written permission to submit a request on your behalf. Additionally, we may require you to verify your identity with us through the verification process detailed below.
Requests to Know and Requests to Delete
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
The specific pieces and categories of personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
sales, identifying the personal information categories that each category of recipient purchased.
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
You also have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request to delete, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
To verify your identity, we require you provide your name and email and you confirm your identity through a confirmation email message. Once submitted, you will receive an email within 10 business days that we will use to verify your identity and provide confirmation of your request. We will respond to your request to know or request to delete within 45 days from the day we receive the request. If necessary, we may extend the time period to a maximum total of 90 days from the day we receive the request. In such case, you will receive an email notifying you of the extension and explaining the reason for the extension. Any disclosure in response to a request to know will cover the 12-month period preceding the business’s receipt of the request and will be delivered in a readily useable digital format.
Your request to know or request to delete may be denied for any reason allowable under the CCPA. For example, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it or any other purpose permitted by the CCPA.
Similarly, we may deny requests:
For specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of that personal information, your account with us, or the security of our systems or networks.
To access or delete information that is de-identified.
If your identity cannot be verified to a degree of certainty required by the CCPA.
From an authorized agent that does not submit proof that they have been authorized by the consumer to act on the consumer’s behalf.
Request to Opt-Out
If you are 16 years of age or older, you have the right to opt-out from a sale of your personal information. We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in"). Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you may submit a request to customer service at .
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Collection of Personal Information
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer (“personal information”).
We may obtain the categories of personal information listed above from the following categories of sources:
Directly from you or your agent.
Indirectly from you or your agent. For example, through information we collect in the course of providing services.
Directly and indirectly from activity on our website. For example, via signups on our Site, such as through the creation of an account.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
To fulfill an order.
To provide you with information, products or services that you request from us.
To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
To improve our Site and present its contents to you.
For testing, research, analytics and development.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
Sharing Personal Information
When we disclose or sell personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We do not sell the personal information of minors under 16 years of age without affirmative consent.
We disclose and sell your personal information for a business purpose to the following categories of third parties:
Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
If you have questions or concerns regarding this Policy, please direct inquiries to customer service at firstname.lastname@example.org.
Personal information does not include:
Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the California Consumer Privacy Act’s (“CCPA”) scope, like:
health or medical information covered by HIPAA and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data (please see our Notice of Privacy Practices for more detail about the privacy of your health information);
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FRCA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994.
Under applicable law, we are permitted to disclose personal information to service providers in accordance with written contracts requiring our service providers to keep the information confidential. In addition to third-party service providers, we share all of the categories of personal information we collect with government entities (if required by law or reasonably necessary to avoid harm).
To opt out of our email marketing or to unsubscribe from our email newsletters, you can contact our customer service department. If you choose to opt out, you will continue to receive all email communications related to our transaction(s) and relationship with you.
If you would like to update your mailing information or want your name and address removed from our direct mailing list, you can contact our customer service department.
As described in this Policy, we may also make your information available to third parties for their direct marketing purposes. Pursuant to California Civil Code § 1798.83, no more than once per calendar year, California residents may request that we send you via mail or email: (1) the categories of personal information disclosed to those third parties; and (2) the names and addresses of those third parties. To request this information, please contact customer service at email@example.com.
Our Site and services are not directed to children under the age of 16 and we do not knowingly collect personal information from children. It is our policy not to knowingly solicit or permit children under the age of 16 to provide their personal information for any purpose. In accordance with the Children's Online Privacy Protection Act of 1998 (“COPPA”) and our internal policies, if a person under age 16 submits information to us through any part of our Site, and we know that the person submitting information is under age 16, we will not use it for any purpose. We will delete the information as soon as we discover it, and we will not disclose it to third parties. If you are under the age of 16, please do not use our Site and its services.
UPDATING YOUR INFORMATION
You may request to view, update, or correct your personal information by contacting customer service at firstname.lastname@example.org. In order to protect your privacy, we will take steps to verify your identity before granting you access to the information or enabling you to make corrections.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
This Policy shall be governed by, and construed in accordance with, the laws of the State of New York without regard to principles of conflicts of laws.
Any dispute, claim or controversy among the parties arising out of or relating to this Policy, except for any provisions relating to a consumer’s rights under the CCPA shall be finally settled by arbitration in New York, New York in accordance with the Consumer Arbitration Rules of the American Arbitration Association then in effect and such resolution shall be final and binding upon the parties.
THE PARTIES AGREE TO WAIVE ANY RIGHT TO TRIAL BY JURY IN ANY CIVIL ACTION ARISING OUT OF OR RELATING TO THIS POLICY. THE PARTIES AGREE TO ARBITRATE SOLELY ON AN INDIVIDUAL BASIS AND THAT THIS POLICY DOES NOT PERMIT CLASS ARBITRATION OR ANY CLAIMS BROUGHT AS A PLAINTIFF OR CLASS MEMBER IN ANY CLASS OR REPRESENTATIVE ARBITRATION PROCEEDING. THE VALIDITY, EFFECT, AND ENFORCEABILITY OF THE FOREGOING WAIVER OF CLASS ACTION LAWSUIT AND CLASS-WIDE ARBITRATION, IF CHALLENGED, ARE TO BE DETERMINED SOLELY AND EXCLUSIVELY BY THE STATE COURTS LOCATED IN NEW YORK, NEW YORK, OR, IF BROUGHT IN A FEDERAL DISTRICT COURT, THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK.
The parties hereto hereby submit to the exclusive jurisdiction of the courts sitting in New York, New York and agree that venue is proper therein (and waive any objection to such venue) for the purpose of compelling arbitration and enforcing any arbitration award entered pursuant hereto.
Without waiving the right to appeal such decision, should any portion of this section be stricken from this Policy or deemed otherwise invalid or unenforceable, then this entire section (other than this sentence) shall be stricken from this agreement and inapplicable, and any and all disputes shall proceed in the state courts located in New York, New York, or, if brought in a federal district court, United States District Court for the Southern District of New York and be decided by a judge, sitting without a jury, according to applicable court rules and procedures, and not as a class action lawsuit.
LINKS TO THIRD PARTY WEB SITES
We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you may contact us.
We have implemented appropriate physical, electronic, and administrative procedures to safeguard and prevent unauthorized access, maintain data security, and correctly use the information we collect online. Please note that there is risk involved in using the internet. Thus, our goal is to provide a reasonable level of security based on general industry standards. We therefore recommend that you use every precaution to protect your information when using the internet and any other links. All transactions occur through our secure server. That means that we use encryption to secure information sent from your computer to our servers. In addition, credit card numbers and other sensitive information are encrypted in our database(s) to provide a second layer of security for your private information. When credit card information is transmitted online, we use Secure Sockets Layer (“SSL”) server software to prevent unauthorized access to the information. SSL is a highly sophisticated method of scrambling data as it travels from your computer to our Website servers. You can identify the secure connection by looking for a locked padlock icon at the lower portion of your browser window.
We do not disclose personal information to any third parties for their direct marketing purposes.
In addition, under California law, web site operators are required to disclose how they respond to web browser 'do not track' signals or other similar mechanisms that provide consumers with the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party web sites, to the extent the operator engages in that collection. We do not respond to any such 'do not track' signals, as no one do not track standard has gained consensus.
This law also requires web site operators to disclose whether third parties may collect personal information about their users' online activities over time and across different web sites when the users use the operator's web site. We do not knowingly permit third parties to collect personal information about an individual consumer's online activities over time and across different web sites when a consumer uses our Site.
Third parties that have content embedded on our Site (such as social networking features) may set cookies on a user's browser and/or obtain information about the fact that a web browser visited our Site from a certain IP address. These third parties cannot collect any other personal information from our Site unless you provide it to them directly.
We will not discriminate against you for exercising any of your California privacy rights under the CCPA. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
CONSUMERS WITH DISABILITIES
To request this Policy in an alternative format, please reach out to us via customer service at email@example.com.
If you have questions or wish to contact us about this Policy, please direct inquiries to:
463 Lincoln Place #224
Brooklyn, New York 11238
These Privacy & Security Policies are effective as of ____________, 2020.