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The following Privacy Notice governs your access to and use of the vionette.netwebsite, including any content, functionality and services offered through it.

In this Notice:

The Administration of the website is Vionette LTD, a company incorporated under the laws of Cyprus, having its company registration number: 644923, and registered address at Evagora Papachristoforou, 4, Themis Court, Office1, Agios Nikolaos, 3030, Limassol, Cyprus, is referred hereto as "Administration", "we", "us" or "Website” and “you” or “your” means you as a user of our website.

We take our obligation to safeguard personal information about our clients seriously.

This Privacy Notice is an addition to Our Terms of Use and should be read in conjunction with the Terms of Use.

By using this website, you agree to be bound by the terms of this Privacy Notice.

We review our Privacy Notice from time to time and reserve the right, at our discretion, to amend this Notice at any time without any notice other than posting the amended Privacy Notice on Our website. Amendments to our Privacy Notice will take effect immediately once posted on our website. Your continued use of our services following the posting of an amended Privacy Notice will be deemed as acceptance of those amendments.

It is your responsibility to ensure that you keep up-to-date with the current Privacy Notice.

You should review this page periodically so that you are updated on any changes to the Notice.

Personal Data we collect

We gather personal data that can identify, relate to, describe, be associated with, or link to a specific consumer or household. Additionally, we may collect non-identifiable and non-associated data, such as aggregated information, which does not fall under the scope of personal data unless stored or linked with personal data.

Categories

The specific types of personal data we collect from our users depend on their interactions with us and their use of the Services:

  1. Identifiers: This includes real names, aliases, postal addresses, IP addresses, email addresses, account names, passport numbers, or similar identifiers.
  2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)).
  3. Characteristics of protected classifications under California or federal law of the United States of America.
  4. Internet or electronic network activity information: This includes browsing history, search history, and data regarding a consumer's interaction with websites, applications, or advertisements on the Internet.
  5. Financial information (i.e., bank details).
  6. Personally submitted preferences.

We do not collect any additional categories of personal data beyond those mentioned above. If we plan to collect additional categories in the future, we will provide you with a new notice prior to or at the time of collection.

How we collect Personal Information

We will collect personal information only according to lawful and fair means. We collect your personal information directly from you unless it is unreasonable or impracticable to do so. We may collect this information when you:

  • Access or use our website;
  • Register an account with us;
  • Register as Content Creator;
  • Use our products and services;
  • Participate in our competitions, giveaways and other promotions;
  • Contact us directly via any medium including SMS, MMS, instant messaging, email, social media platforms, postal mail and telephone;
  • Provide feedback through our website/app feedback links; and

Personal information may also be collected by cookies when you use our website. See our Cookie Policy here.

Why do we collect, hold, use and disclose personal information

We collect, hold, use and disclose personal information for purposes including the following:

  • to provide products and services to you;
  • to enable us to perform our obligations to you under the Terms of Use, and to ensure that you perform your obligations under the Terms of Use;
  • for communicating with you, including sending you information about our products and services;
  • for planning, research, promotion and marketing of our goods and services, including conducting competitions or promotions;
  • to create aggregate data about clients through demographic profiling and statistical analysis of our database to optimise our products and services and /or allow for more efficient operation of our business;
  • to prove your good faith;
  • for the investigation of suspected unlawful, fraudulent or other improper activity connected with the use of our products and services.

To whom Personal Information is disclosed

By registering with Us and providing personal information you consent to your personal information being used by us.

We may disclose your personal information to third parties as follows:

  • to our contractors and external service providers associated with the operation of our business and provision of our services including, without limitation, associated data centres, web hosting providers, payment service providers, advertising agencies, mailing houses, printers, call centres, market research analysts, IT consultants, professional advisors and consultants;
  • to law enforcement agencies to assist in the prevention of criminal activities;
  • to government and regulatory authorities and other organisations as required or authorised by law or otherwise;
  • controlling bodies where such controlling bodies request information to protect and maintain the integrity of services provided or where we consider any activity to be suspicious or unusual; and
  • to a successor entity in the event of a business transition, such as a merger, corporate reorganisation or to a purchaser of part of or all of Our assets.

Should the information be transferred to a third party, we will use reasonable measures to ensure that the information disclosed is protected by the third party under contractual arrangements.

What are your rights?

The rights mentioned in this paragraph applies to all users visiting our website, and specifically to users from the European Union, United Kingdom and Switzerland.

You have the following rights regarding the processing of your personal data, given to you through General Data Protection Regulation (GDPR):

  • The right to be informed. You have a right to be informed about how your personal data is processed in a concise, transparent, intelligible and easily accessible manner, written in clear and plain language, that is free of charge. This is the purpose of this Privacy Notice.
  • The right of access. You have the right to obtain confirmation that your data is being processed and to have access to that personal data. You can request this sending email to support@vionette.net.
  • The right to rectification. You have the right to have your personal data rectified if it is incorrect or incomplete and we must notify any third parties that we have shared your data to do the same. You can request this sending email tosupport@vionette.net.
  • The right to erasure. You have a “right to be forgotten”, or to have your personal data erased and to prevent processing. The right is not absolute and in certain circumstances, this may not be possible (for example where we have to keep your personal data for legal or regulatory reasons). We must notify any third parties that have been shared your data of your request. You can request this sending email to support@vionette.net.
  • The right to restrict processing. You have the right to ‘block’ or suppress the processing of your personal data. This does not stop the storing of your personal data, as it may be required to restrict processing in the future. We must notify any third parties that have shared your data of your request. You can request this sending email to support@vionette.net.
  • The right to data portability. You have the right to obtain and reuse your personal data for your own purposes across different services in a safe and secure way, without hindrance to usability. You can request this sending email to support@vionette.net.
  • The right to object. You have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); direct marketing (including profiling); and processing for purposes of scientific/historical research and statistics. You can request this sending email to support@vionette.net.
  • Rights in relation to automated decision making and profiling. You have a right to object to automated decision making, to express your point of view, ask for human intervention, and to be provided with an explanation of the decision with your option to challenge it. You can request this sending email to support@vionette.net.
  • The right to withdraw consent. If you have given us explicit consent to process your personal data you have a right to withdraw that consent at any time, including but not limited to the removal of consent to be contacted for marketing purposes. You can request this sending email to support@vionette.net.
  • The right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint with us directly and / or with a supervisory authority. You can find their contact details here.

California Residents Rights

This paragraph expands the list of applicable rights only to residents of California.

California Civil Code Section 1798.83 grants certain privileges to our users who are California residents. You have the option to request and receive from us a comprehensive list of any personal data, if applicable, that we have shared with third parties for their direct marketing endeavours during the previous calendar year. This list will include the names and addresses of those third parties.

Please note that you are allowed to make such requests only once per year, per person. To submit your request, kindly use the email support@vionette.net. It is important to mention that there will be no charge for this service. However, we want to assure you that we do not disclose personal data protected under the "Shine the Light" law to third parties for their own direct marketing purposes.

Moreover, as part of the California Consumer Privacy Act ("CCPA"), we extend additional rights to our users who are California residents. These rights are as follows:

  • Right to Know: You possess the right to request specific information about the personal data we have collected, used, disclosed, and sold about you within the past 12 months. This encompasses the right to know any or all of the following details:
    • The categories of personal data collected about you.
    • The categories of sources from which we obtained your personal data.
    • The categories of personal data we have sold or disclosed about you for business purposes.
    • The categories of third parties to whom your personal data was sold or disclosed for business purposes.
    • Our business or commercial purpose for collecting or selling your personal data.
    • The specific pieces of personal data we have collected about you.
    • Data Portability: You have the right to request a copy of the personal data we have collected and retained about you in the past 12 months.

    We value your privacy and are committed to ensuring the protection of your personal information. If you have any concerns or would like to exercise any of these rights, please don't hesitate to reach out to us.

  • Right to Deletion: You maintain the right to request the deletion of your personal data that we have collected and retained, with certain exceptions. It's important to note that we may deny your request or retain certain elements of your personal data if it is necessary for us or our service providers to:
    • Complete the transaction for which the personal data was initially collected, provide a requested good or service, or fulfill a contract between our business and you that is reasonably anticipated within the context of our ongoing relationship.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • Debug to identify and rectify errors that impair the existing intended functionality.
    • Exercise the right to free speech, uphold the right of another consumer to exercise their right to free speech, or exercise another right provided by law.
    • Comply with the California Electronic Communications Privacy Act as outlined in Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest, as long as it adheres to all other applicable ethics and privacy laws. In certain cases where the deletion of the information would render the achievement of such research impossible or significantly impaired, we may retain the information if you have provided informed consent.
    • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
    • Comply with a legal obligation.
    • Otherwise, use the personal data internally in a lawful manner that is compatible with the context in which you provided the information.
  • Right to Opt-Out/In: You have the option to opt out of or opt-in to the sale of your personal data, although we want to clarify that we do not sell your personal data.
  • Right to Non-Discrimination: You hold the right to be free from discriminatory treatment by us for exercising your CCPA privacy rights. We will not, unless permitted by the CCPA:
    • Deny you goods or services.
    • Charge you different prices or rates for goods or services, including applying discounts or other benefits, or imposing penalties.
    • Provide you with 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.

To exercise your California privacy rights as outlined above, please send an email to support@vionette.net.

If you have an existing account with us, you can exercise any of the aforementioned rights directly from your profile. In the event that you don't have a profile or encounter difficulties accessing, controlling, or deleting your information through your profile, please reach out to us using any of the contact methods provided above.

Please note that only you or a person authorized by you to act on your behalf can make a verifiable consumer request regarding your personal data.

For the Right to Know or Data Portability, you may submit a verifiable consumer request twice within a 12-month period. The verifiable consumer request should include the following:

  • Provide sufficient information that enables us to reasonably verify your identity as the person about whom we have collected personal data or as an authorized representative. Depending on the nature of the request, we may require an additional SumSub verification cycle, which involves a government-issued ID and a photo requiring your presence (refer to the Identity Verification section below for further details).
  • Clearly describe your request with enough detail to ensure a proper understanding, evaluation, and response.

We reserve the right to deny your request if we are unable to verify your identity or have reason to believe that the request is fraudulent.

Your Vionette LTD Privacy Rights:

Vionette LTD law grants Vionette consumers the right to request that their personal data not be sold, even if their personal data is not currently being sold. You can submit such requests by emailing us at support@vionette.net. These requests are free of charge.

Identity Verification

In cases when you decide to become a “Creator”, we will be obliged to verify your identity and age. In order to ensure the protection of your personal information, our identity verification process will include the use of SumSub, a trusted third-party service, which requires you to provide a government-issued ID and submit a photo that confirms your presence.

Please be assured that we take your privacy seriously and employ these measures to safeguard your personal data.

If an authorized agent submits a consumer request on your behalf, we require the following items to confirm their authority and verify their identity. Please have an email sent to support@vionette.net containing:

  • Proof that you have given the authorized agent signed permission to submit the request.
  • Sufficient information to verify the authorized agent's identity, depending on the nature of the request.

To verify your identity, we may also require a valid government-issued ID (not expired), email address, and the last 4 digits of your social security number (applicable to US residents), depending on the nature of the request.

Please note that we cannot respond to your request or provide personal data unless we can verify your identity or authority and confirm that the personal data relates to you. Creating an account with us is not necessary to make a verifiable consumer request. However, if you have an existing login, you will be required to log in to submit a request. Personal data provided in a verifiable consumer request will only be used for the purpose of verifying the request's identity or authority.

Once we receive your request, we will acknowledge its receipt within ten (10) business days. We will respond to your verifiable consumer request within thirty (30) days of receiving it, or forty-five (45) days if the request submitted from residents of the State of California. If additional time is required (up to 90 days), we will notify you in writing, providing the reason for the extension. If you have an account with us, our written response will be delivered through that account. If you don't have an account, we will deliver our response electronically. Any disclosures we make will cover the 12-month period preceding the receipt of your verifiable consumer request. Our response will also explain the reasons if we are unable to comply with a request. For Data Portability requests, we will provide the relevant information in a portable and readily usable format, to the extent technically feasible, allowing you to transmit the information to another entity without hindrance.

We do not charge a fee for processing or responding to your verifiable consumer request, unless it is excessive, repetitive, or manifestly unfounded. If we determine that a fee is warranted, we will provide an explanation for the decision and estimate the cost before completing your request.

Security of Personal Information

We will take reasonable steps to protect the personal information we collect and ensure that it is accurate, complete and up-to-date.

Your information is held on secure servers. We may also store personal information in hard copy or paper files.

Our employees, agents, contractors are required to maintain the confidentiality of all personal information.

Access to and correcting Personal Information

We take reasonable measures to ensure that the personal information we collect about you is accurate, up-to-date and complete. We also take reasonable steps to ensure that the personal information we use or disclose is accurate, up-to-date, complete and relevant.

If we are under the impression that your personal information should be corrected, we will take reasonable steps to correct it – this may include contacting you to ask you to provide your most current information.

You may request access to and correction of the personal information we hold about you. We will require you to verify your identity and to specify what information you require.

Personal Data retention

Your information is held on secured servers. We may also store personal information in telephone recordings and in hard copy or paper files.

Our employees, agents, contractors are required to maintain the confidentiality of all personal information.

We understand the importance of security and techniques needed to secure information. We store all of the Personal Information we receive directly from you in a protected database residing within our secure network, behind active state-of-the-art firewall software. Moreover, we do not store or process credentials of payment cards.

The amount of time we hold your information depends on the reason it was provided. Your data will not be kept indefinitely and will only be kept for as long as is required for legitimate business reasons (for example to provide you with our Services or for the other reasons we explained above) and in order for us to comply with our legal and regulatory obligations.

The personal information we receive when you make an application (whether on our website or which comes to us via one of the websites of our affiliates) is kept for a minimum of six years, which will commence at the end of the relationship. We are required to do so to ensure that if any disputes or complaints are raised, we have your information to enable us to address the complaints or disputes.

If you request that we do not contact you for advertising and marketing reasons, we will need to keep your information as this would reflect your preferences.

To request details relating to your personal data retention, please use the following email address: support@vionette.net.

Overseas transfer of personal information

There may be instances where we may be required to send your personal information overseas or collect personal information from overseas, including:

  • where you have asked us to do so;
  • when we have outsourced a business activity or function to an overseas provider with whom we have a contractual arrangement; or
  • where we are required or authorised by law to do so.

We may disclose your personal information to entities located outside your country of residence, including the following:

  • external service providers.

Unsolicited personal information

Where we receive unsolicited personal information, we will determine whether or not it would have been permissible to collect that personal information if it had been solicited. If we determine that collection would not have been permissible, to the extent permitted by law, we will destroy or de-identify that personal information as soon as practicable.

Non-Personal Information

Like most websites, we may collect non-personal information from your use of our websites in order to assist with the administration of our websites, to track site usage and to enhance your user experience.

Once logged in your IP address is tracked against your user ID for the purposes of preventing fraud, identifying improper activity connected with the use of our products and services, and creating an audit trail. We collect and store non-personal information that we collect through cookies, log files or web beacons to create a profile of our users. A profile is stored information that we keep on individual users that detail their viewing preferences. This profile is used to tailor a user’s visit to the Our site, and to direct pertinent marketing promotions to users.

Modification of this Privacy Notice

This Privacy Notice supersedes any previous disclosures we have provided regarding our information practices for the Services. We reserve the right to modify, alter, or update this Privacy Notice at any time, and any such changes will become effective when we post the revised Privacy Notice. We will make reasonable efforts to notify you of material changes to our processing activities and/or this Privacy Notice, such as by posting a notice on the Services or sending you an email. By continuing to use the Services after we have posted a revised Privacy Notice, you acknowledge and accept the updated Privacy Notice.

Applicability

This Privacy Notice is subject to the Terms of Service and Acceptable Use Policy that govern your use of the Services. It applies to all information provided or accessed through the Services, regardless of the means used.

However, this Privacy Notice does not cover information collected by third-party services, applications, or advertisements associated with or linked from the Services. The collection or receipt of your information by such third parties is governed by their own privacy policies, statements, and practices. We are not responsible or liable for any third party's compliance with their privacy policies.

Complaints

If you have a complaint relating to how we handle personal information, please contact our support at support@vionette.net.