GET CLEVER ABOUT VO | COOKIE POLICY

COOKIES POLICY

A cookie is a text file that contains an identifier (a string of letters and numbers) that is sent by a web server and kept by the browser. Each time the browser requests a page from the server, the identification is delivered back to the server. Cookies are classified as “persistent” or “session” cookies. A persistent cookie will be saved by a web browser and will remain valid until it is destroyed by the user before the expiry date; on the other hand, a session cookie will expire when the web browser is closed at the conclusion of the user session. Cookies do not usually contain information that can be used to personally identify a user, but the personal information that we store about you may be linked to information stored or obtained from cookies.

We use cookies for the following purposes:

  • authentication – we use cookies to identify you when you visit our Site and as you browse and/or navigate our Site;
  • active status – we use cookies to help us to determine if you are logged into our Site and/or to remember and process items in your cart;
  • security – we use cookies as a security protocol to protect your account, including preventing fraudulent use of login credentials, and to protect our Site and services generally;
  • advertising – we use cookies to tailor our advertisements to be relevant to you; and
  • analysis – we use cookies to help us to analyze the use and performance of our Site and services.

Most browsers allow you to refuse to accept and/or delete cookies. The methods for doing so vary from browser to browser, and from version to version.  However, you can obtain updated information regarding blocking and deleting cookies via the following:

Please note that the blocking or disabling of certain cookies may have a negative impact on the functions or features of our Site.  That is, some features of our Site may not be available to you if you choose to block or disable certain cookies.

RETENTION & PROTECTION

We will only keep your personal information for as long as you want to stay connected with us.  As this time will vary, there is no precise duration to provide.  As a general rule, however, we will continue to send you email messages and newsletters via our email subscription (which you either signed up for or were automatically enrolled via other activities on our Site) until you opt out of these emails.

For payment and sensitive credit/debit card information, we use a Secure Socket Layer (SSL) certificate (technically a Transport Layer Security aka “TLS certificate”), which is an encryption security protocol to protect this information. The SSL/TLS certificate encrypts this data and ensures that anyone who intercepts the data can only see a scrambled set of characters and the information is safe and only visible to the website in which it was entered.  We do not store or process this information personally on our server, but instead use a third-party service provider. 

We use safeguards that are commercially responsible and accepted in the industry to protect your personal information. You acknowledge that we cannot prevent all misuse and unauthorized access to your personal information and hold us harmless should your personal information be tampered and/or intercepted without your or our consent.  This includes a release of all claims associated with the unauthorized third-parties’ use of said information.

Should a data breach occur, we will promptly notify you within 10 business days of the known breach unless you reside in the United Kingdom and/or the European Union, which requires notices of a serious data breach within 72 hours after we become aware of said breach.

You may have additional rights depending on where you live, please refer to sections below regarding “Territories”.

PASSWORD USE & PROTECTION

You may be required to create an account with a username and/or password to login and access certain features and/or content on our Site, or to use certain products or services.   You are solely responsible for maintaining the confidentiality of your account’s login credentials (i.e. username and password).  Additionally, you are solely responsible for any activities, by you or others, that may occur through your account and accessed via your login credentials.

We are not liable for any unauthorized use of your account or security information or breaches of your account due to the unauthorized use of your login credentials.  We highly recommend that you log out of your account after each session ends to prevent unauthorized use or access.

You are not authorized to share your account or login credentials with anyone other than yourself so that others may not gain unauthorized access to our Site or Content via your account and/or login credentials.

You may have additional rights depending on where you live, please refer to sections below regarding “Territories”.

YOU ARE IN CONTROL

If you want to see if we have your personal information and what we have about you, if you want to rectify or update your information, or if you want us to delete your personal information, please contact us at the email below.  Note, we reserve the right to refuse your request should we believe the requested changes to be false, incorrect or fraudulent in nature.

Additionally, if you want to unsubscribe from our email list, simply click on the unsubscribe button on the bottom of our emails and follow the instructions.  Please note that if you have subscribed to more than one list, then you will need to unsubscribe from each and your opting out may not guarantee that you have been removed from each list.  If you experience any issues unsubscribing, please contact us for prompt removal at the email below.

TERRITORIES

Our computer systems, Site and hosted servers are based in the United States of America (“U.S.”) and the Content on our Site is directed only to U.S. residents. Additionally, we may use third-party processors, including payment providers, located in the U.S. As such, your personal and non-personal information may be transferred internationally to and stored on the servers in the U.S.  Said information is also processed by us in the U.S.  Please note that data protection and privacy regulations may or may not be equal to the level of protection as in other areas throughout the world, such as in Canada, the European Union or the European Economic Area, the United Kingdom, amongst others.

 

By visiting the Site, you unequivocally agree to us collecting and processing your personal and non-personal information in the U.S., the transfer, processing and storage of your personal and non-personal information from your jurisdiction to the U.S., and that only U.S. laws will govern such collection and processing. 

Depending on where you reside, however, you may be entitled to additional rights as follows:

GENERAL DATA PROTECTION REGULATION (“GDPR”)

If you live in the European Union (“EU”) or the European Economic Area (“EEA”), then your personal information may fall under the GDPR.

We will only process and/or collect your personal information as follows:

  • Consent: you will NOT be automatically enrolled in our email list to receive messages and/or newsletters unless you affirmatively consent to the same. You can also opt out of any data collection technology by activating the “Do Not Track” setting in your browser and/or declining the cookies feature and unsubscribing from our emails;
  • Retention: we will not keep your personal information for any longer than is necessary. You have the right to access, update or delete your personal information from our records and can contact us at the email below;
  • Date breaches: we will notify you of any data breaches within 72 hours;
  • Legitimate interests: we will only process your personal information to engage in legitimate business interests, such as entering into a contract with us or for the performance and/or enforcement of a contract, communicating with you, providing our products and/or services to you and your interaction with our Site.

If you have concerns, questions or requests about how we process personal data, write to us at the email address below. If we are not able to adequately address your concerns, you can address them to the data protection Supervisory Authority in your country, pursuant to Article 77 GDPR.

UNITED KINGDOM’S GDPR (“UK GDPR”)

If you live in the UK, then your personal information may fall under the UK GDPR and the Data Protection Act of 2018 (“DPA 2018”). 

The DPA 2018 sets out the personal information data protection framework for UK residents and replaces the Data Protection Act of 1998, coming into effect on May 25, 2018.  Note, it was amended on January 1, 2021 to reflect the UK’s status as outside of the EU. It supplements the UK GDPR, by providing exemptions, extending data protection to national security and defense and sets out the Information Commissioner’s powers/functions.  

The UK GDPR is a UK law that became effective on January 1, 2021.  It is based on the EU/EEA GDPR, which used to apply to the UK before January 1, 2021, with some changes. 

If your personal information was collected before January 1, 2021 (referred to as “legacy date”), then it will still be subject to the EU/EEA GDPR as of December 31, 2020 (aka “frozen GDPR”).  As of now, no significant changes exist between the frozen GDPR and UK GDPR and, thus, please refer to the above section entitled “GENERAL DATA PROTECTION REGULATION (“GDPR”) for your additional rights prior to January 1, 2021.

We will only process and/or collect your personal information as follows:

  • Consent: you will NOT be automatically enrolled in our email list to receive messages and/or newsletters unless you affirmatively consent to the same. You can also opt out of any data collection technology by activating the “Do Not Track” setting in your browser and/or declining the cookies feature and unsubscribing from our emails;
  • Retention: we will not keep your personal information for any longer than is necessary. You have the right to access, update or delete your personal information from our records and can contact us;
  • Date breaches: we will notify you of any data breaches within 72 hours;
  • Legitimate interests: we will only process your personal information to engage in legitimate business interests, such as entering into a contract with us or for the performance and/or enforcement of a contract, communicating with you, providing our products and/or services to you and your interaction with our Site.

If you have concerns, questions or requests about how we process personal data, write to us at the email address below. If we are not able to adequately address your concerns, you can address them to the data protection Commissioner in your country.

BRAZIL’S LGPD (“BRAZIL’S GDPR”)

If you live in Brazil, then your personal information may fall under Brazil’s LGPD (Lei Geral de Protecao de Dados Pessoais – often referred to as “Brazil’s GDPR”).  Brazil’s GDPR was signed into law and has been effective since September 18, 2020.  The laws are drafted and based on the EU/EEA’s and UK’s GDPR. 

We will only process and/or collect your personal information as follows:

  • Consent: you will NOT be automatically enrolled in our email list to receive messages and/or newsletters unless you affirmatively consent to the same. You can also opt out of any data collection technology by activating the “Do Not Track” setting in your browser and/or declining the cookies feature and unsubscribing from our emails;
  • Retention: we will not keep your personal information for any longer than is necessary. You have the right to access, update or delete your personal information from our records and can contact us;
  • Date breaches: we will notify you of any data breaches within a reasonable time;
  • Legitimate interests: we will only process your personal information to engage in legitimate business interests, such as entering into a contract with us or for the performance and/or enforcement of a contract, communicating with you, providing our products and/or services to you and your interaction with our Site.

If you have concerns, questions or requests about how we process personal data, write to us at the email address below. If we are not able to adequately address your concerns, you can address them to the Data Protection Officer in your country.

CALIFORNIA RESIDENTS

If you reside in California, your personal information entitles you to additional rights and may be governed under the California Online Privacy Protection Act (CalOPPA”) and the California Consumer Privacy Act (“CCPA”).

CalOPPA: A “Do Not Track” (“DNT”) is a setting that can be activated on certain browsers to block behavioral tracking from third-party services, such as Google Adwords.  Your browser may allow you to automatically transmit a DNT signal to websites that you visit.  Please note, there is no consensus in the industry as to what constitutes a DNT.  Currently, we do not alter our practices if it receives a DNT signal from your and/or a visitor’s browser. To learn more about DNT visit: http://www.allaboutdnt.com.

CCPA: You have the right to request what we have regarding your personal information and of which has been collected over the last 12 months from the date of your formal request.  Upon receipt, we will disclose:

  • The categories of personal information we collected about you;
  • The categories of sources for the personal information we collected about you;
  • Our business and commercial purposes for collecting that information;
  • The categories of third-parties with whom we shared your personal information;
  • The categories of personal information disclosed for a business purpose in the preceding 12 months; and
  • The specific pieces of personal information we collected about you.

You also have a right to request that we delete this same information, subject to certain exceptions.  Please contact us at the email address below for such a request.

VIRGINIA RESIDENTS

If you reside in Virginia, your personal information entitles you to additional rights and may be governed under the Virginia Consumer Data Protection Act (VCDPA). 

Virginia residents have the right to request access, correction, deletion, and sale-opt-out of their personal data. You can exercise these rights by contacting us at the email address below with your request or any questions you may have. We will respond within 45 days.

We will not sell your personal data without your consent. We will only share your personal data with third parties who are necessary to provide our services to you. We will take all reasonable steps to protect the privacy and security of your personal data.

TEXAS RESIDENTS

If you reside in Texas, your personal information entitles you to additional rights and may be governed under the Texas Data Privacy and Security Act (“TDPSA”).

Texas residents have the right to: (i) request that we disclose the categories and specific pieces of your personal data that we have collected about you in the past 12 months; (ii) request that we delete your personal data, subject to certain exceptions; and (iii) opt-out of the sale or sharing of your personal data for targeted advertising purposes.

You can exercise these rights by contacting us at the email address below with your request or any questions you may have. We will respond to your request within forty-five (45) calendar days.

CHILDREN’S PRIVACY

Protecting children’s privacy is important to us. We don’t collect personal information from anyone under 13. If you’re a parent or guardian and believe your child has provided us with personal information, please let us know.  Should we discover that a person under 13 years of age has provided their personal information to us, we will delete their personal information as governed by the Children’s Online Privacy Protection Act of 1998 (“COPPA”). 

CAN-SPAM ACT OF 2003 COMPLIANCE

In compliance with the CAN-SPAM Act of 2003, all unsolicited commercial emails from the Company will clearly state the sender of the email, a legitimate physical address of the Company, a relevant subject line, that the email is an advertisement or a marketing solicitation and will include a visible and operable unsubscribe mechanism below the message to be honored within 10 business days.

CHANGES TO THE PRIVACY POLICY

We reserve the right, in our sole discretion, to change, modify, revise, amend, or otherwise alter in any way this Privacy Policy, our Site, and/or its Content at any time without notice to you.  Should any such changes or revisions occur, the most recent version will be posted on the Site, and will become effective immediately.  By using the Site or Content after the date posted above, you are deemed to have consented to the revised/updated Privacy Policy. 

Should any material changes occur to our Privacy Policy, we will contact you via email or by a prominent message on our Site.

CONTACTING US:

If you have any questions about this Privacy Policy, your rights, the practices of this Site, or would like to update/remove your personal information, please contact us as follows:

  • By emailing us directly at: admin@getcleveraboutvo.com
  • By mail: Lili Wexu Ent., Inc.18034 Ventura Blvd #2019, Encino, CA 91316, United States

 

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