Effective Date: January 1, 2020
WHAT INFORMATION DOES THE SITE OBTAIN?
VIP Sample Club collects two basic types of information from you – personal information and non-personal or anonymous information. Personal information is defined as information that relates to, describes, references, or is reasonably capable of being associated with a particular consumer, household or device, but does not include publicly available information from governmental records or deidentified or aggregated consumer information. Non-personal or anonymous information is defined as information that is non-identifiable and that is unable to be used to identify a consumer, household or device.
Within the last twelve (12) months, we have collected different categories of personal information from different sources, as described below:
User Provided Information: When you register with us or use the Site, you may provide us certain information voluntarily, such as identifiers or commercial information. This may include: (a) identifiers, such as your name, mobile or residential phone number, zip code, e-mail address, postal address, date of birth, age, gender; (b) responsive information when you answer survey questions, register for an offer or the Site, or enter into sweepstakes or contests, such as your age, sex, employment information, commercial information, or education; (c) information you provide us when you contact us; (d) information you enter into our system when using the Site, such as contact information which is clearly labeled at the time you submit it; and (e) information you post on our Site. We collect this information from you in order to provide you with the Services described within our Site and to deliver you with newsletters, orders, or other information or services as requested.
Automatically Collected Information: When you use the Site, we automatically collect certain information from you, such your Internet or similar network activity. For example, we may collect Internet or other similar network activity, such as your Internet addresses, browser type, Internet Service Provider (ISP), referring and exit page, operating system, timestamps, clickstream data, the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, and your mobile operating system. We also track and analyze non-identifying and aggregate usage and volume statistical information from our visitors and customers. This information is logged and used for purposes such as to help diagnose technical problems and to administer our Site so that we can constantly improve it.
Cookies: Cookies are small data files placed in your browser. Cookies transmit information such as session ID, user ID, and conversion data. This information helps website providers recognize a browser or mobile device and helps us gather information such as how many users have visited our site and which pages and advertisements have been seen and clicked on. We use first-party cookies and third-party cookies together to report ad impressions, other uses of ad services, and interactions with ad impressions related to your visit to our Site. Such information is used to tailor your experience on our Site.
Third-Party Analytics: We may collect certain information via third-party analytics services that may collect your non-sensitive user information. This may include: the information you provide us, your session ID, your user ID, your interest data, and conversion data. These third parties may collect hashed user data directly from emails or communications using cookies, web beacons, or other similar technologies on behalf of VIP Sample Club and/or for unaffiliated marketing purposes. This information provides us with tools to calculate the numbers and frequency of visitors on the Site and to understand how you and other users use the Site so to improve your experience.
Google Analytics: We enable Google Analytics to support Display Advertising. We have implemented the following Google Analytics features to support Display Advertising: Remarketing, Google Display Network Impression Reporting, DoubleClick Campaign Manager integration, Google Analytics Demographics and Interest Reporting. You may opt out of Google Analytics for Display Advertising and customize Google Display Network advertisements at http://www.google.com/settings/ads
- Remarketing with Google Analytics: We use Remarketing with Google Analytics to advertise online. Third-party vendors, including Google, may show our ads on sites across the Internet. Both ourselves and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your past visits to our website.
- Google Display Network Impression Reporting and DoubleClick Campaign Manager integration: Both ourselves and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our site.
- Google Analytics Demographics and Interest Reporting: We use data from Google's Interest-based advertising or third-party audience data (such as age, gender, and interests) with Google Analytics to match you with the right message and show you advertisements that are more relevant to your interests.
Data Providers and Internet-Based Advertising: We may work with data providers and third-party advertisers who may collect web log data from you (including IP address and information about your browser or operating system), place, or recognize a unique cookie on your browser to enable you to receive customized ads, personalized e-mail or content. Such cookies do not contain any personally identifiable information, but reflect de-identified demographic or other data linked to the data you voluntarily submitted to us (e.g. your e-mail address that is shared solely in hashed, non-human readable form).
HOW IS THE COLLECTED INFORMATION USED AND SHARED?
When we disclose or sell personal information for a business purpose, we enter into 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 for performing the contract. We share and/or sell your information with the categories of third parties as listed below:
Third-Parties: We work with several Third Parties, such as service providers, data brokers or aggregators, advertisers, and Internet cookie data recipients. VIP Sample Club may share and/or sell some of your information with these Third Parties to provide you with the best deals and offers available that we believe will be of interest to you. You may see any of these Third Party Advertisers’ ads or offers on the Site or on websites, applications, and services operated by the Third Party Advertisers. When signing up for the Site, you may be asked to complete a survey. You may be shown a Third-Party Advertisers’ offer while completing the survey. You may choose to skip any offer shown to you or you may choose to provide your information in response to the offer. When you respond to any offer shown, we will transfer some or all of the information that you submit during the website registration process to the Third-Party Advertiser.
Other Data Sharing: In addition, we may share information that we collect with our vendors or service providers who help us operate our business; in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; when we believe disclosure is necessary to investigate, prevent, or take action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property, or safety of our company, our employees, our web site users, or others; or to enforce our website terms and conditions or other agreements or policies. We may also transfer any data we collect in connection with a corporate change such as a merger, our acquisition by another company, or a partial or total sale of our assets (including as part of a bankruptcy proceeding).
WHAT ARE MY CHOICES ON HOW THE INFORMATION IS USED?
We provide options regarding the information shared with us, depending on the service:
VIP Sample Club Newsletter: You may unsubscribe from receiving emails from us by clicking the "Unsubscribe" link in the email you receive. You may also unsubscribe by sending an email to [email protected] Please allow up to ten (10) days for us to process your unsubscribe request.
Mobile Communications. If you no longer wish to receive telephonic communications via your mobile device, you may unsubscribe at any time by texting "STOP" in response to the message(s) you receive. You may receive a confirmation message or further instructions on how to completely unsubscribe if you have registered to multiple mobile offers. You may also text "HELP" in response to the message(s) you receive to get more information.
User Content: If you post any User Content on any public areas of our Site, you understand that there is no reasonable expectation of privacy for such information and it may be seen by other users or the public. If you would like any User Content removed, contact [email protected]
Do Not Track: At this time, we collect information from you for the purpose of tracking your online activities over time and across third-party websites or online services, thus, we do not respond to "Do Not Track" signals or frameworks requesting an alteration to our online tracking of individual users who visit our Site or use our services.
Internet-Based Advertising: Our Site and newsletters may include third party advertising and links to other websites. We may work with third party advertising networks and advertisers who help deliver these ads to you and who may collect information about your browsing activity over time and across different sites in order to make this advertising more relevant. Some of these ads may be personalized, meaning that they are intended to be relevant to you based on information we or the online advertising network collects about your online activities here and elsewhere over time.
Although you may not opt out of receiving online advertising generally, you may control the collection of data on our Site used for targeted advertising during your visits to other websites. You may visit www.aboutads.info to learn more about this type of advertising and how to opt out of this advertising on websites. Please note that opting out of third-party behavioral advertising will not prevent advertisements from appearing in your browser or applications but will not be relevant to you or your interests. In addition, note that if you use a different browser or erase cookies from your browser, you may need to renew your opt-out choice.
CALIFORNIA PRIVACY RIGHTS
Access to Specific Information and Data Portability Rights
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 twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collect about you
- The categories of sources for the 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
- The specific pieces of personal information we collected about you (also called a data portability request)
- If we sold your personal information for a business purpose, two separate lists disclosing:
- Sales, identifying the personal information categories that each category of recipient purchased; and
- Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that VIP Sample Club delete any of your personal information that we collected from you and retained, subject to certain exceptions listed within the CCPA (for example, if we need to complete a transaction or detect security incidents). 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.
Exercising Access, Data Portability, and Deletion Rights
In order to make a verifiable consumer request as described above, please submit a verifiable consumer request to VIP Sample Club by either:
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. In order for VIP Sample Club to properly process your request, please ensure that your verifiable consumer request:
- Contains sufficient information that allows VIP Sample Club to reasonably verify that you are the person about whom we collected personal information or an authorized representative.
- You will need to provide us with your e-mail address that you used to register with VIP Sample Club and your physical mailing address for VIP Sample Club to verify your identity.
- Describe your request with sufficient detail that allows VIP Sample Club to properly understand, evaluate, and respond to your request.
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. We will only use the personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We will make our best efforts to respond to a verifiable consumer request within forty-five (45) days of receipt. If we require more time to respond, we will let you know the reason and the extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with the request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your requests unless the requests are excessive, repetitive, or unfounded. If we determine that your request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
You have the right to direct us to not sell your personal information at any time (the right to "opt-out"). Consumers who opt-in to the sale of their personal information may opt-out of future sales at any time. To exercise your right to opt-out, you may submit a request to us by visiting the following Internet Web Page link: "DO NOT SELL MY PERSONAL INFORMATION". Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by registering with VIP Sample Club again. We will only use your personal information provided in an opt-out request to review and comply with the request.
VIP Sample Club will not discriminate against you for exercising your CCPA rights. Unless permitted by the CCPA, we will not: deny you goods or services, charge you a different price for goods or services, provide you with a different level or quality of goods or services, suggest that you may receive a different price for goods or services, or suggest that you may receive a different level or quality of goods or services.
UPDATING YOUR INFORMATION
If you’d like to access, update, or delete information that you have provided via the Site, please contact us at [email protected] or the address below and we will respond in a reasonable time. Before we are able to provide you with any information, correct any inaccuracies, or delete any information, however, we may ask you to verify your identity. Please note that some or all of the information may be required in order for the Site to function properly and we may be required to retain certain information by law.
We take reasonable and appropriate measures to help prevent the loss, misuse, and alteration of your information by carefully limiting access to the database in which your personal information is stored. Even though we follow reasonable procedures to try to protect the information in our possession, no security system is perfect, and we cannot promise, and you should not expect, that your information will be secure in all circumstances.
The Site is not directed to children under the age of 13 and we do not knowingly collect personal information from children under the age of 13. If we become aware that we have inadvertently received personally identifiable information from someone under the age of 13, we will delete such information from our records.
LINKS TO OTHER SITES
To reach the owner of the website, contact:
VIP Sample Club
P.O. Box 12630 San Diego, CA 92112-3630