VLGE privacy policy
Updated: 25th March, 2024
Thank you for visiting VLGE.
This Privacy Policy describes the personal data handling policies of VLGE, as a data controller, with respect to visitors of our website at www.vlge.com (the “Website”), registered individual users of our VLGE Platform (the “Platform”, and together with the Website, the “Services”), and the personnel and representatives of VLGE’s corporate customers (referred to as “Corporate Customers”) using our Services. “You” or “User” as used in this Privacy Policy means our individual users and the authorized personnel and representatives of our Corporate Customers.
This Privacy Policy does not address the privacy practices of the Corporate Customers and the data collected by Corporate Customers from their users (“Corporate Customer Users”), in which role VLGE is a processor of personal information contained in Corporate Customer data. If you are a Corporate Customer User using the Platform provided by a Corporate Customer, please understand that VLGE and the Corporate Customer are independent parties, and VLGE has limited or no control over the Corporate Customer’s privacy practices. Please review the privacy policy of such Corporate Customer to understand its practices and direct any questions or concerns to the Corporate Customer contact.
This Privacy Policy describes the following:
1. What personal data we collect from users of our Services;
2. How we use the data;
3. With whom we may share the personal data;
4. Legal basis for processing the data;
5. Storage and security of your data;
6. Your Privacy Rights, Choices and Disclosures, including those for Europe and California; 7. Users outside the United States; and
8. Links to other sites;
9. Privacy Policy updates; and
10. Contact Information.
1. Personal Data We Collect or Process
(a) The Services capture some information about you automatically utilizing background local storage and session storage technologies (“Cookies”). Cookies are small files or other pieces of data which are downloaded or stored on your computer or other device, that can be tied to information about your use of the Services (including certain third party services and features offered as part of our website). Examples of information of this type are your IP address, the browser you are using, the operating system you are using, the pages on the website that you visit and details of your transaction activity, such as the amount, date and time for each transaction. When we use Cookies, we may use “session” Cookies that last until you close your browser or “persistent” Cookies that last until you or your browser delete them. You may change your browser setting to decline the use of Cookies.
Some third-party providers may place Cookies on your browser or hard drive. Note that this Privacy Policy does not cover the use of Cookies by such third parties. Proper working of the Services requires full browser permissions that could potentially be used to access additional personal information. Such browser permissions are used for an extremely limited technical purpose for allowing VLGE to properly interact with your browser. Most web browsers are set to accept Cookies by default, but you can usually set your browser to remove or reject Cookies. If you do choose to remove or reject Cookies, however, your ability to use the Services may be affected.
We use Google Analytics, a web analytics service of Google Inc. (“Google”) which uses Cookies to identify the frequency of use of certain areas of our Website and to identify preferences. For more information regarding how Google collects, uses, and shares your information, please visit http://www.google.com/policies/privacy/partners/. The information regarding your use of this Website that is generated by the Cookie (including your truncated IP address) is transferred to a Google server in the United States and stored there. Google will use this information to analyze your use of the Services, compile reports on activity for us, and perform further services associated with Website use and Internet use. Google may also transmit this information to third parties where required by law or to the extent that third parties process these data on behalf of Google. You can deactivate Google Analytics using a browser add-on if you do not wish the analysis to take place. You can download the add-on here: https://tools.google.com/dlpage/gaoptout?hl=en.
We use Stripe, a payment processing tool of Stripe Inc. To ensure secure and reliable transactions, Stripe handles your payment information. This includes credit card details like number, expiry date, and CVV code. It's important to note that we, at VLGE, do not store this sensitive data on our servers. Stripe, a trusted payment processor, adheres to stringent security protocols to safeguard your financial information.
In addition to payment details, Stripe collects your billing information, including your name, address, and email address. This information is essential for verifying your identity and completing the payment process.
For more information please visit https://stripe.com/in/privacy
We leverage Mixpanel to gain valuable insights into how users interact with our platform. The data collected anonymously by default can include the pages you visit, the features you utilize, and the duration of your sessions. If you create an account with us, this anonymous data may be linked to your personal information.
The data collected on your device, such as operating system, browser type, and IP address, is also gathered by Mixpanel. This information helps us understand user behavior patterns on our platform and identify potential issues for improvement.
For more information please visit https://mixpanel.com/legal/privacy-policy/
We operate social media pages on third party networks and have social media icons on our Website. When you visit or link to our social media pages, data is processed both by us and the applicable social media provider. Social media providers are unaffiliated with us, and we are not responsible for the content or privacy practices of social media providers. Social media providers have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit their websites or interact with their platforms.
We collect information about plugins you might be using, including but not limited to those related to the management of cryptocurrency assets.
(b) We also collect information that you provide to us voluntarily.
VLGE collects the information that you provide to us when you sign up to receive newsletters, advisories, announcements and invitations and contact us by email. We use this information only to respond to your comments, requests or questions.
In the provision of the Services, VLGE may, without limitation, process the following categories of personal data:
- User data, such as username, e-mail address, voice data (where applicable), chat data (where applicable), and data related to blockchain accounts, such as private keys associated with smart contracts or ownership status of digital items (where applicable).
- Profile data, including profile image, cover/banner image, username, email ID (not displayed on site, for internal use only), biography (250 character maximum), Instagram handle, Twitter handle and website link.
- Transaction data payment method and payment card number (depending on the payment method), transaction time, account number (depending on the payment method), and billing details.
If you inquire about a career at VLGE, you have the option of sending to us a resume containing personal data about you and which we will use solely for employment evaluation purposes. Providing this information is completely voluntary. Please do not submit to us any sensitive personal information.
We do not knowingly collect information from users of our website under the age of 18 and/or their internet usage, and such persons are not authorized to use the Services. If we obtain actual knowledge that a user is under 18, we will take steps to remove that user's personal information from our databases. By using the Services, you represent that you are at least 18 years old. You also represent, by accessing or using the Services, that you are of legal age to enter into legal agreements, or if you are not, that you have obtained your parent’s or legal guardian’s consent to accept the terms in this Privacy Policy.
2. How We Use the Data
We use the personal data we collect to respond to your inquiries, complete transactions you initiate, provide the Services you request, including but not limited to facilitating your cryptocurrency transactions through wallets, enhance the Services, perform our contractual obligations, provide updates and other important information related to your activity on and with the Services, inform you of new services or changes in Services, administer the Services, fill employment positions, enter into contracts for services, to fulfill legal obligations we have to governmental authorities or other third parties, and for other legitimate business purposes.
3. With Whom We Share Personal Data
VLGE may share information with internal personnel and our affiliates located in different geographic locations in order to perform our Services. We may also share your personal data with third parties (within or outside your country of residence) who perform services on our behalf, including without limitation our blockchain provider, payment processors, technology providers and professional advisors.
Transactions are completed via third party non-custodial web3 wallets which are connected to the blockchain (Venly and Metamask). Both of these services utilize other companies for their fiat-onramps (i.e., allowing users to load cryptocurrencies into their wallet via credit/debit card purchases). VLGE does not collect or store any of this information.
- Stripe (https://stripe.com) provides a set of programmable APIs and tools to let you facilitate payments and pay out sellers globally.
- MixPanel (https://mixpanel.com/) is an event analytics service company that tracks user interactions with web and mobile applications
VLGE may disclose any information we have about you (including your identity) if we determine that such disclosure is necessary in connection with any investigation or complaint regarding your use of the Services, or to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) VLGE’s rights or property, or the rights or property of visitors to or users of the Services. VLGE reserves the right at all times to disclose any information that VLGE deems necessary to comply with any applicable law, regulation, legal process or governmental request. VLGE also may disclose your information when VLGE determines that applicable law requires or permits such disclosure, including exchanging information with other companies and organizations for fraud protection purposes.
We may share your data with a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, liquidation or other disposition of all or any portion of our business, assets or stock with such third party.
We may share aggregated and de-identified information with third parties (within or outside your country of residence) for analytical, research or other similar purposes.
VLGE may obtain your written consent from time to time in electronic form by using online agreements or other acknowledgements on the Services, including for any other contemplated uses of your personal data not addressed in this Privacy Policy. Please read all online agreements carefully before accepting them.
4. Grounds for Using Your Personal Data
We rely on the following legal grounds to process your personal information:
Consent. Some uses of your personal data as described in this Privacy Policy are subject to your consent, such as marketing email communications and the use of Cookies. You may opt out of marketing communications by clicking on the “unsubscribe” link at the bottom of the communication. You may refrain from providing, or withdraw, your consent for Cookies via your browser and mobile settings.
Performance of a contract. We may need to collect and use your personal information to enter into a contract with you and to perform Services that you request.
Legitimate Interests. We may use your personal information for our legitimate interests to provide our Services and to improve our Services and the content contained thereon. We may use technical information as described in this Privacy Policy and use personal information for our marketing purposes consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable law.
Compliance with Legal Obligations. We may use your personal information as necessary to comply with our legal obligations.
5. Storage and Protection of Your Personal Data
We retain the personal data we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected and to perform our contractual and legal obligations. Notwithstanding the generality of the foregoing, we store email addresses until the user requests to be unsubscribed or removes themselves through any self-service tools offered to the user.
We do not store payment card information; rather we utilize third party platform and payment processors and store only an electronic receipt that sets forth confirming payment details, such as purchase date, the expiration date of the payment card and the payment ID, but not complete payment card information.
We take reasonable administrative, physical and technical precautions to protect your personal data and communications between us. This includes, when required or as we deem appropriate and feasible under the circumstances, encryption and written commitments from third parties that may have access to your data that they will protect the data with reasonable safeguards.
No Internet or e-mail transmission is ever fully secure or error free, however. We therefore cannot guarantee absolute security of your data, and we are not responsible for processes and networks that we do not control. Users assume the risk of security breaches and the consequences resulting from them. Please be careful in deciding what information you send to us via email or over the Internet.
6. Your Rights, Choices and Disclosures
(a) General. This section is subject to specific disclosures on privacy rights set forth below. We are committed to facilitate the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale of your personal information (as applicable). We will do our best to honor your requests subject to any legal and contractual obligations. If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you Services, contact us at hello@vlge.com or make changes to any user profile information connected to your account.
You may opt out of receiving electronic marketing communications from us by clicking on the “unsubscribe” link on the communication or contacting us at hello@vlge.com. Some non-marketing communications may not be subject to a general opt-out, such as communications about transactions, disclosures to comply with legal requirements, software updates and other support-related information. If you do not wish to receive any service-related emails from us, you have the option to deactivate your account.
Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority.
You may be able to disable Cookies through your browser settings, but if you delete or disable Cookies, you may experience interruptions or limited functionality in certain areas of the Services.
(b) Your European Privacy Rights and Choices. If you are located in the European Union, the United Kingdom or another jurisdiction that has adopted the General Data Protection Regulation (GDPR) or laws substantially similar to GDPR, your privacy rights include the following:
- Transparency and the right to information. Through this policy we explain how we use and share your information. However, if you have questions or need additional information you can contact us any time.
- Right of access, correction, restriction of processing, erasure. You may contact us to request information about the personal data we have collected from you and to request the correction, modification or deletion of such personal information, which requests we will do our best to honor subject to any legal and contractual obligations. To make a request or to ask us a question about our data practices, please contact us via email at hello@vlge.com.
- Right to withdraw your consent at any time. When we process your personal data based on your consent, you have the right to withdraw it at any time.
- Right to object at any time. You have the right to object at any time to receiving marketing or promotional materials from us by either following the opt-out instructions in commercial e-mails or by contacting us, as well as the right to object to any processing of your personal data based on your specific situation. In the latter case, we will assess your request and provide a reply in a timely manner, according to our legal and contractual obligations. Some non-marketing communications are not subject to a general opt-out, such as communications about transactions and disclosures to comply with legal requirements.
- Right to data portability. You have the right to data portability of your own personal data by contacting us.
- Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your personal data that may negatively impact you.
- Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes your privacy rights according to the European Privacy regulation, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement.
(c) California Disclosures
California “Shine the Light” Information-Sharing Disclosure: California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to hello@vlge.com with “California Shine The Light Rights” in the subject line.
California Do Not Track Disclosure: At this time, there is no worldwide uniform or consistent industry standard or definition for responding to, processing, or communicating Do Not Track signals. Thus, our Online Services are unable to respond to Do Not Track Signals.
California Consumer Privacy Act Disclosures. VLGE is not a business subject to the California Consumer Privacy Act.
7. Users Outside the United States
In connection with your use of the Services, personal data may be stored and processed in the United States. If you are an individual from Europe, Canada or any other jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that we may store the information we collect in the United States which is not deemed an “adequate jurisdiction” by the European regulatory authorities. Personal data may also be transferred from the country of your residence to other countries, including the United States.
8. Links to Other Sites
Our Services may contain links to other websites for your convenience or information. These websites may be operated by companies unaffiliated with VLGE, and we are not responsible for the content or privacy practices of those websites. Linked websites may have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit the websites.
9. Privacy Policy Changes
We may update this Privacy Policy from time to time and without prior notice to you to reflect changes in our information practices, and any such amendments shall apply to information already collected and to be collected. Your continued use of the Services after any changes to our Privacy Policy indicates your agreement with the terms of the revised Privacy Policy. Please review this Privacy Policy periodically and especially before you provide personal data to us. The date of the last update of the Privacy Policy is indicated at the top of this Privacy Policy.
10.Questions and Contact Information
Please contact us if you have any questions about our Privacy Policy. You may contact us by sending correspondence to the foregoing address or by emailing us at hello@vlge.com