Like most businesses, Velvet Caviar holds and processes a wide range of information about its customers and other persons who may be interested in Velvet Caviar's services.
This privacy notice applies to all Velvet Caviar operations, and explains the type of information that we process, why we are processing it and how that processing may affect you.
The privacy notice is split into the sections listed below. This page explains what we mean by “personal data”, “processing”, and other terms used in this notice.
We may update this privacy notice from time to time, and will post any revised notice on this web page. Where appropriate we may notify you by email or by a notice on our website that our privacy notice has changed but we recommend that you check this page regularly. Any changes will be immediately effective on posting.
We believe privacy is a right, and you have a right to keep it private. Our goal is to be transparent about how we collect and use information about you, to keep such information secure, and to provide you with meaningful choices.
WHAT THIS POLICY COVERS
- What information we collect and why we collect it.
- How we use that information.
- The choices we offer, including how to access and update information about you.
To help you understand what personal information we collect about you, here is a summary of the primary information we collect:
- If you log in, we collect your email address to create a Velvet Caviar ID.
- We collect information on the advertising identifier to provide you targeted advertising.
- If you use the Velvet Caviar website, we collect information through cookies to provide you targeted advertising, and your IP address to help control email spam and abuse management.
- We collect anonymized data for analytics purposes such as hardware and operating system information, performance statistics, and data about how you use your devices and applications.
- Location data in non-European Economic Area countries.
Velvet Caviar (“we”, “our”, or “us”) is a New York corporation located in the United States of America. We are an aggregator of websites and communications platforms (“Service”). Velvet Caviar operates the Service at https://www.velvetcaviar.com.
The Service is hosted in the United States and is available through the Website and is not directed to individuals under the age of sixteen (16). Velvet Caviar does not knowingly collect information from individuals under sixteen (16) years of age without prior parental consent or consistent with applicable law.
CROSS BORDER DATA TRANSFERS
TRANSPARENCY AND CHOICE
People have different privacy concerns. We believe you should have tools to control information about you and manage your experience with us. For example, you can find controls to manage or review your account information, marketing preferences, and collection of location data by going to your Profile Settings on the App or Website. If you opt out of receiving targeted ads, you will continue to see ads, but they may not be as relevant or useful to you. For more information on ads and how to opt out, see the section below headed “Advertisements; Ad Networks; Other Third Parties”.
INFORMATION WE COLLECT
We collect information to better provide the Services to our users - from tailoring your experience with the Application and Websites such as showing you content we think you might be interested in, making recommendations of Sites to follow, to advertising, measuring advertising performance, and related research.
We may collect and combine information when you interact with the Service, including:
Information you give us. We collect the information that you voluntarily give us. For example, when you register for a Velvet Caviar ID, we ask for your email address and may request other registration information required by a Site to register as a member.
- Information from your use of the Service. We collect information about how you use a Website and Application like which Sites or Users you follow, and the content you view. This information includes:
- Device information: such as your IP address and an anonymous device identifier. In addition, the Application collects certain information automatically, such as content viewed, and information that allows us to periodically determine mobile device and usage information, which may include (i) information about the way you use the Application, (ii) information specific to your mobile device (such as make, model, operating system and version, Internet browser, device IP address, cookies, anonymous device and/or advertising identifier and similar information), (iii) information about your use of features, functions, or notifications on the device, and (iv) signal strength relating to WiFi or Bluetooth functionality, temperature, battery level, and similar technical data. We may collect the foregoing information even if you are not logged in to the Application;
- Browser information: such as information automatically provided by browsers like user agent and IP addresses accessing a Website; and
- Location information: for users outside the European Economic Area, such as information that allows us to periodically determine your actual location. We may collect the foregoing information even if you are not logged in to the Application. For iOS users, you should be able to adjust the settings on your iOS device to prevent collection of location information by disabling the location services feature on your device. For Android users, you should be able to adjust your settings on your Android device to prevent collection of location information by disabling Bluetooth and location service features on your device.
- Information from others: If you use Facebook or Google + to log in to the Application or a Website, we collect your email address and profile picture. These services will authenticate your identity and provide you the option to share (or not share) certain information with us to create a Velvet Caviar ID. Services like Facebook give you the option to post information about your activities using the Service to your Facebook profile page to share with others within your Facebook network.
We do not any “sensitive” or “special categories of personal data” as defined under European data protection laws.
HOW WE COLLECT USER INFORMATION
- Web beacon; tags; pixels: are blocks of code that can read and place cookies, recognize certain types of information on your device, such as which websites or apps you use, and your browsing behavior, as well as provide Service analytics; and
- Mobile device identifiers: are standard device identifiers, for example the “IDFA” advertising identifier used on Apple’s iOS devices and the “Google Advertising ID” advertising identifier used on Android devices, to analyze your use of mobile applications.
HOW WE USE THE INFORMATION COLLECTED
We use the information collected to provide the Service and personalize your use of the Service. For example, we use the information collected for tailoring your experience with the website such as showing you content we think you might be interested in, and making recommendations of Sites to follow. Such information may be used by itself, aggregated, or combined with other information from third parties. We may also use information collected to deliver you information and/or promotional materials about Velvet Caviar and/or to carry out other purposes that are disclosed to you, and to which you consent.
We may also use the information collected for the following purposes:
- To send your username and email, and if requested by a Site, birthdate and other responses to questions required to register for the Site(s) you choose to follow so that you become a member of that Site. You agree to comply with the rules, regulations, end-user license agreement, and terms of service of each such Site. If you do not want to allow other users to follow you or your threads, please contact our customer support team at email@example.com
- To contact you in connection with the Service, which may include sending you periodic updates on trending discussions from the Sites you follow, if you receive a “like” for one of your posts to a Site, and/or if you were quoted in a post on a Site. You may opt-out of receiving promotional mailings from us by following the instructions set forth in the Email Opt-Out section below;
- To log you into the Application with the information we receive from your use of Facebook Login or Google + as described above;
- To provide user support and site administration;
- To improve the Service;
- To enable advertising and standard advertising controls;
- To measure and report on advertising performance, trend analysis, and pattern detection;
- To protect the safety and security of users of the Service or members of the public including acting in urgent circumstances;
- To protect or defend the legal rights or property of Velvet Caviar, advertisers and other third parties, including business partners such as advertising businesses, as well as our corporate affiliates, in connection with the Service;
- To investigate, deter, and report against fraudulent, unauthorized, or illegal activity, and/or risk management; and
- To comply with applicable law, rules, regulations, or legal process.
SHARING THE INFORMATION COLLECTED
We share the information collected as follows:
- Advertisers: We share information collected with advertisers and other third parties, including business partners such as advertising businesses who are obligated to comply with applicable laws concerning usage of the information, as well as our corporate affiliates, in connection with the Service (such third parties and affiliates collectively, “Affiliates”). In addition, our Affiliates may share this information with their own third-party business partners who may use the information either for themselves or on behalf of the applicable Affiliate, each only for the purposes set forth in the section above headed “How We Use Information Collected”;
- Service providers: We share information collected with our service providers to facilitate some aspects of the Service or perform functions on our behalf. These service providers may use information about you solely for the purpose of providing these services to us or on our behalf;
- Sites you choose to follow: We share your name, username, and email with the Site(s) you choose to follow so that you become a member of that Site;
- Legal and other purposes: We may share information collected with law enforcement, regulatory authorities, courts with competent jurisdiction, emergency services, or other necessary third parties for legal, protection, security, and safety purposes;
- Business transfers: We may share information collected in connection with the sale or transfer of all or a part of our business or assets to a third party buyer.
INFORMATION OUR VENDORS AND OTHER THIRD PARTIES COLLECT
ANALYTICS SERVICE PROVIDERS
- We may allow certain third party analytics service providers to collect the anonymous data received from cookies and web beacons on our behalf, and to retain and use this data themselves. In addition, we may allow these service providers to include web beacons within the pages of the Websites and anonymous identifiers on the Application. We may also share portions of our log file data, including IP addresses, with these service providers for analytics purposes. These service providers aggregate information about what you see and interact with on the Websites and on the Application.
ADVERTISEMENTS; AD NETWORKS; OTHER THIRD PARTIES
- We may allow certain third party companies to serve advertisements to you and collect anonymous information regarding your use of the Service. Typically, these companies are third party ad servers, ad agencies, technology vendors, providers of sponsored content, and research firms, and they may include cookies and web beacons within the Websites, or other tracking methodologies such as anonymous device identifiers on the Websites and/or within the Application to collect anonymous information in order to provide customized content and/or ads of interest, auditing, research and reporting for us, our partners, and advertisers when you visit certain pages of the Websites or Application, and other websites or applications. For example, because your web browser requests these advertisements and/or web beacons from the third-party’s web servers, these companies can view, edit or set their own cookies, just as if you had requested a webpage from their website directly. When you view or interact with an advertisement, the possibility exists that these companies will make the assumption that you are interested in the subject matter of the advertisements.
- In addition, we or our data partner(s) may collect and store a unique identifier matched to your mobile device, in order to deliver customized ads or content while you use the Service or other websites or applications, or to seek to identify you in a unique manner across other devices or browsers. In order to customize these ads or content, we or our data partner(s) may connect de-identified demographic or other data about you (received from third parties) either to data you voluntarily submitted to us (such as your email address), or to data automatically collected from you (such as your device identifier or IP address). However, we will only share your email address with our data partners in hashed, non-human readable form.
LEGAL BASIS FOR PROCESSING INFORMATION (EEA USERS ONLY)
If you a user located in the European Economic Area, our legal basis for collecting and using the information described above depends on the type of information concerned and the specific context in which we collect it.
We may rely on our legitimate interest to collect information from you, except where such interests are overridden by your data protection interests or fundamental rights and freedoms. Where we rely on our legitimate interests to collect and process information about you, they include the interests described in the section above headed “How We Use the Information Collected”.
However, in some cases, we may rely on your consent or have a legal obligation to collect the information from you, or may otherwise need the information to protect your and/or our vital interests or those of another person or entity. If we rely on your consent to collect and/or process information about you, we will obtain such consent in compliance with applicable laws.
If you have questions about or want further information concerning the legal basis on which we collect and use information about you, please contact us using the details in the “Contact Information” section below
EUROPEAN DATA SUBJECT RIGHTS
If you are a resident of a country in the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the collection, processing, and use of information about you. As set forth above, the information that we collect about you when you use the Service may include certain digital identifiers that are considered “personal data” under European law. We process this data either as it is necessary to further our legitimate interest and/or pursuant to your consent.
As a resident of a country in the EEA, you have the right to: (i) request access and obtain a copy of the information we collect about you; (ii) request rectification or erasure; (iii) restrict the processing of such information; and (iv) if applicable, data portability. In certain circumstances, you may also have the right to object to the processing of such information.
If you would like to exercise any of these rights, please contact us using the details in the “Contact Information” section below. Please note that because most of the information we collect and maintain about you can only identify a particular browser or device, and cannot identify you individually, you may need to provide us with additional information to enable us to identify the information we have about you and ensure that we accurately fulfill your request. Although we use good faith efforts to respond to your request, we may not be able to provide and/or correct the requested information in all situations. For example, we may not be able to provide the information requested if it imposes an undue burden or expense, requires us to release confidential commercial information, or requires the disclosure of information relating to another person.
Finally, as a resident of the EEA, you have the right to lodge a complaint about our processing of personal data with a European Data Protection Authority. For contact details of your relevant local Data Protection Authority, please see here: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
CLOSING YOUR ACCOUNT; DELETING INFORMATION
Our goal is delete the Velvet Caviar account you requested within 30 days of receiving your written request. For the Website, we will delete your email, IP address, username and your profile information. Because we do not control all other Sites, please contact the Site owner to delete your account information.
If you close your Velvet Caviar account, we will use reasonable efforts to ensure that information about you is no longer accessible or used by the Service. However, as permitted by applicable law, we retain and may use information about you as necessary to comply with our legal and/or financial obligations, resolve disputes, enforce our agreements, and other legitimate purposes (including, for document retention and security purposes). Please contact us using the details in the “Contact Information” section below to close your Velvet Caviar account or request changes or modification of the information you previously provided to us.
Velvet Caviar uses industry-standard physical, electronic, and procedural measures designed to safeguard the information in our possession against loss, theft and unauthorized use, disclosure, or modification. However, please note no transmission of information via the Internet or electronic storage solution can be guaranteed to be completely secure, although we take reasonable precautions to protect against security incidents.
RETENTION OF INFORMATION
We do not store information longer than we need it. The cookies we set expire no later than 30 days after they were last accessed. We typically store the information collected, such as IP address and other information described above until the next login. When we no longer need the information collected, it is deleted from either the cookies or our servers (as applicable).
In some cases, we may keep some information for longer periods of time where required under certain laws or to comply with law enforcement or regulatory requests, which for example may include, those relating to corporate governance, taxation, money laundering and financial reporting legislation.
EMAIL OPT OUT
You may opt-out of receiving promotional emails from us, by clicking on the “unsubscribe” link in the emails you receive from us.
RESIDENTS OUTSIDE OF THE EUROPEAN ECONOMIC AREA:
Attn: Privacy Officer
5 Brewster St.
Glen Cove, NY 11542
EUROPEAN ECONOMIC AREA RESIDENTS:
Attn: Data Protection Officer
5 Brewster St.
Glen Cove, NY 11542
Important note: The data controller of European Economic area residents’ information is Velvet Caviar at the above address.
NEW YORK PRIVACY RIGHTS
Residents of New York have the right to request from a business, with whom the New York resident has an established business relationship, what types of personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information in the immediately preceding calendar year. To access this information, please contact us either by email at firstname.lastname@example.org or at the address below:
Attn: Data Protection Officer
5 Brewster St.
Glen Cove, NY 11542
You can opt-out from being tracked by Google Analytics with effect for the future by downloading and installing Google Analytics Opt-out Browser Addon for your current web browser: https://tools.google.com/dlpage/gaoptout
last updated: 05-24-18