Privacy Policy

PRIVACY POLICY

This Privacy Policy (the “Privacy Policy” or “Policy”) discloses how VUUM collects, discloses, transfers and otherwise uses your personal information to provide our products and services. Please take a moment to read through this Policy in its entirety.

“VUUM”, “we”, “us” or “our” means VUUM Technologies LLC, a Delaware limited liability company with its principal place of business located at 9903 S Santa Monica Blvd #762, Beverly Hills, CA 90212. 

If you have any questions, concerns or complaints regarding this Privacy Policy or our processing of your personal information or you wish to submit a request to exercise your rights regarding the collection and use of your personal information, you can do so by contacting us via e-mail: hi@drinkvuum.com.

1 HOW WE USE AND COLLECT YOUR PERSONAL INFORMATION

We act as controller for the personal information we gather through your use of our website.

“Personal Information” is defined as any information relating to an identified or identifiable natural person. Identifiable refers to identifiers (such as name, identification number, location data, etc.), that can be used to directly or indirectly identify a natural person.

When you visit the Site, we automatically collect certain information about your device, such as your IP address, device ID and type, referral source, language settings, browser type, operating system, geographical location, length of visit, page views, or information about the timing, frequency and pattern of your service use. As you browse the Site, we also collect information about the individual web pages that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site, including responses to surveys or other communications or feedback that you provide. We refer to this automatically-collected information as “Device Information.” This information may be aggregated and used to help us provide more useful information regarding the use of our website. In the event the usage data is completely anonymized (and can therefore not be traced back to you as an individual), this will not be considered personal information for the purpose of this Privacy Policy.  

We collect Device Information using the following technologies:    

  • “Cookies” are data files that are placed on your device or computer that store preferences and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.    
  • “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.    
  • “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

Additionally, if you register with our Site, we will collect personal and other information from you directly when you provide it to us through the Services, including your email, phone number, and location. We refer to this information as “Personal Identification Information.”  Our Services are intended to be used by individuals who are at least 18 years old, and we will not knowingly seek to collect Personal Identification Information from individuals who are under 18 years old.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Personal Identification Information.

The following are categories of personal information collected:

  • Contact data: in the event you make use of the contact form, you will be asked to provide the following information: name, address, e-mail address, phone number, and any personal information that you choose to put in the designated blank field (please do not provide us with any sensitive information, such as health information, information pertaining to criminal convictions, or credit card/account numbers). This is information that is provided directly by you.
  • Profile data: If you create an account on our website, we collect the following data: name, telephone number, e-mail address, address, country, company name, job title, industry. This is information that is provided directly by you.
  • Newsletter: If you register for our newsletter, you will be asked to provide your e-mail address. This is information provided directly by you.
  • Transaction data: We collect personal information relating to transactions that you make through the website, including your “contact data”, payment information and the goods and/or services purchased. This is personal information provided directly by you.
  • Identifiers such as name, resources, sales inquiry, partner inquiry, subscription to our newsletter: name, telephone number, e-mail address, address, country. This is personal information provided directly by you.
  • Customer Records Information such as credit/debit card number used to pay for goods.
  • Characteristics of Protected Classifications such as age to determine permitted use of our services.
  • Commercial Information such as your purchase history.
  • Device Information and Usage Data: We collect personal data regarding your activities on our website. 
  • Geolocation data such as to determine the applicability of regional legislation permitting the purchase of certain products based on your device’s location.
  • Professional or employment-related information such as employer or workplace to determine any logistical requirements for shipping or delivery.
  • Inferences such as product flavor or fragrance preference.

The personal information we collect is used for the purposes as listed hereunder:

  • In the event you use the contact form on our website, we will use your personal information in order to reply to your query, via e-mail or telephone.
  • In the event you create a profile on our website or you provide us with transaction data, we collect your personal information in order to save such information, to provide you with our services and permit us to receive your information or to contact you.
  • In the event you register for our newsletter, your e-mail address will be used in order to send you our newsletters, which may include invites to events, seminars, etc. organized by us.
  • We process your personal information for the purpose of supporting the website, mobile applications, advertising experience, and enhancing your user experience, which includes ensuring the security, availability, performance, capacity and health of these systems.
  • We process your personal information to enforce or exercise any rights that are available to us based on the applicable law, such as use for the establishment, exercise or defense of legal claims.
  • We may also use your personal information to fulfil our obligations as set out by the applicable law.

We will only collect and process personal information about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g., to deliver the Services you have requested) and “legitimate interests.”

We collect your personal information to deliver our products and services, for example to allow you to purchase our products, create an account and receive discounts, to respond to your inquiries, to send you communications about VUUM, and to conduct interest-based marketing and other online and onsite promotional activities.

Data categories that may be used or disclosed for business purposes:

  • Identifiers such as name, shipping address, or billing address. For example, if we use a 3rd party carrier to deliver your order.
  • Customer Records Information such as credit/debit card number used to pay for goods. For example, if we use a 3rd party payment processor.
  • Characteristics of Protected Classifications such as age. For example, in some cases, your age may be required to determine permitted use of our services.
  • Commercial Information. For example, your order detail will be required for a 3rd party logistics provider to fulfill your order.
  • Internet or other Electronic Network activity information such as your use of our website in terms of browsing and search history. For example, 3rd party monitoring services may be used to ensure operational effectiveness of our services.
  • Geolocation data such. For example, location data may be used to determine the applicability of regional legislation permitting the purchase of certain products based on your device’s location.
  • Professional or employment-related information. For example, if you place a subscription order for your work, office, etc, we may use employment-related information such as work address for delivery and logistics.
  • Inferences such as product flavor or fragrance preference.

Where we rely on your consent to process personal information, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you reside in the designated countries and have any questions about the lawful basis upon which we collect and use your personal information, please contact hi@drinkvuum.com with specific attention to Data Protection Officer.

Your personal information will solely be used for the purposes as set out in this section.

2 SHARING YOUR PERSONAL INFORMATION

We share your personal information with third parties to help us use your personal information, as described above.  We may share your personal information with our third-party service providers who use that information to help us provide our Service. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.  We use the following categories of service providers:

Google Cloud as website host - https://policies.google.com/privacy

We use your personal information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.  For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. You can opt out of targeted advertising by:

Facebook - https://www.facebook.com/settings/?tab=ads    
Google - https://www.google.com/settings/ads/anonymous    
Bing - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

We also use analytic services, such as Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your personal information here:  https://www.google.com/intl/en/policies/privacy/.  You can also opt-out of Google Analytics here:  https://tools.google.com/dlpage/gaoptout.

We do not disclose your personal information to our social media partners. We do, however, make use of social media plugins to direct you to our social media channels and to allow you to interact with our content. These social media channels are (Facebook, Instagram, LinkedIn, Twitter, Google+, Vimeo, TikTok, and Pinterest). In the event you click such link, such social media service provider may collect personal information about you and may link this information to your existing profile on such social media.

We are not responsible for the use of your personal information by such social media service provider. In such case, the social media service provider will act as controller. For your information only, we have included the relevant links (these may be changed from time to time by the relevant service provider):

Facebook: http://facebook.com/about/privacy;
Instagram: https://help.instagram.com/155833707900388;
LinkedIn: http://linkedin.com/legal/privacy-policy;
Twitter: http://twitter.com/privacy;
Pinterest: http://policy.pinterest.com/en/privacy-policy.
TikTok: https://www.tiktok.com/legal/privacy-policy?lang=en 
Klaviyo: https://www.klaviyo.com/legal 
Attentive:https://www.attentivemobile.com/privacy/ 

 We have never, nor will we ever, sell your personal information.

We may also share your personal information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights, as well as for remarketing and targeted advertising.

3 RETENTION OF YOUR DATA AND DELETION

Your personal information will not be kept for longer than is necessary for a specific purpose. However, considering it is not possible for us to specify a period in advance, the period of retention will be determined as follows:

  • To provide you with information, products or services that you request from us or which we feel may interest you;
  • To carry out our obligations arising from any contracts entered into between you and us, including for billing and collection;
  • If you pay for Services or Goods using a credit card, we will transmit your credit card data to the appropriate credit card company and/or credit card payment processing company;
  • To allow you to participate in interactive features of our Services and Goods, when you choose to do so;
  • To contact you about our Services and Goods;
  • In any other way we may describe when you provide the information or when we prompt you regarding a new use of information about you; and
  • To present content from our Services and Goods in an effective manner for you and for your computer or mobile device.

In the event you withdraw your consent or you object to our use of your personal information, and such objection is successful, we will remove your personal information from our databases. Please note that we will retain the personal information necessary to ensure your preferences are respected in the future.

The foregoing will, however, not prevent us from retaining any personal information if this is necessary to comply with our legal obligations, in order to file a legal claim or defend ourselves against a legal claim, or for evidential purposes.

4 YOUR RIGHTS

This section lists your principal rights under data protection law. We have tried to summarize them for you in a clear and legible way.

If you would like to discuss or exercise such rights, please contact us through the contact information below. As part of submitting a request, we will ask for your name, email address, phone number, date of birth, and mailing address. We will respond to your request without undue delay, but in any event within one month of the receipt of the request. In the event of an extension of the term to respond or in the event we do not take action on your request, we will notify you.

Access

  • You have the right to confirmation as to whether or not we process your personal information and, in the event we do so, you have the right to access such personal information, together with certain additional information that you also find listed in this Privacy Policy.
  • You have the right to receive from us a copy of your personal information we have in our possession, provided that this does not adversely affect the rights and freedoms of others. The first copy will be provided free of charge, but we reserve the right to charge a reasonable fee if you request further copies.

Rectification

  • If the personal information we hold about you is inaccurate or incomplete, you have the right to have this information rectified or, taking into account the purposes of the processing, completed.

Erasure (right to be forgotten)

  • In some circumstances, you have the right to the erasure of your personal information without undue delay. Those circumstances include:
    • The personal information are no longer needed in relation to the purposes for which they were collected or otherwise processed;
    • You withdraw your consent, and no other lawful ground exists;
    • The processing is for direct marketing purposes;
    • The personal information have been unlawfully processed; or,
    • Erasure is necessary for compliance with EU or California law.
  • There are certain exclusions to the right to erasure.  Those exclusions include where processing is necessary,
    • for exercising the right of freedom of expression and information;
    • for compliance with a legal obligation; or,
    • for the establishment, exercise or defense of legal claims.
    • The right to restrict processing

Restrict processing 

  • You have the right to restrict processing of your personal information (meaning that the personal information may only be stored by us and may only be used for limited purposes), if:
    • You contest the accuracy of the personal information (and only for as long as it takes to verify that accuracy);
    • The processing is unlawful and you request restriction (as opposed to exercising the right to erasure);
    • We no longer need the personal information for the purposes of our processing, but you require personal information for the establishment, exercise or defense of legal claims; or,
    • You have objected to processing, pending the verification of that objection.
  • We will inform you before we lift the restriction of processing.

Data portability

  • To the extent that the legal basis for our processing of your personal information is consent, and such processing is carried out by automated means, you have the right to receive your personal information from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
  • You also have the right to have your personal information transferred directly to another company, if this is technically possible, and/or to store your personal information for further personal use on a private device.

Object to processing

  • You have the right to object to the processing of your personal information on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:
    • The performance of a task carried out in the public interest or in the exercise of any official authority vested in us;
    • The purposes of the legitimate interests pursued by us or by a third party.
  • If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
  • You have the right to object to our processing of your personal information for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal information for this purpose.

Non-Discrimination

  • We will not discriminate against for exercising any of these rights.

Complain to a supervisory authority

  • If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. 

5 CALIFORNIA RESIDENTS

California residents have certain rights in relation to their Personal Information pursuant to the California Consumer Privacy Act (CCPA). However, these rights are not absolute, and in certain cases we may decline your request as permitted by law. These include the right to:

  • Request information about the Personal Information that we collect about you and the manner in which we use, process and disclose that information;
  • Obtain the specific pieces of Personal Information that we have collected about you in the 12 months preceding your request, including:
    • The categories of Personal Information that we have collected.
    • The categories of sources from which we collected Personal Information.
    • The business or commercial purpose for collecting and/or selling Personal Information.
    • The categories of third parties with whom we share Personal Information.
    • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
    • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.;
  • Request a copy of the Personal Information that we have collected about you during the past 12 months;
  • Delete certain Personal Information that we have collected about you;
  • Opt-out of disclosures of your Personal Information to third parties under certain circumstances;
  • Not be discriminated against as a result of exercising any of the aforementioned rights

If you are a California resident, the Shine the Light Act, Cal. Civ. Code 1798.83 permits you to request information regarding the disclosure of your personal information to third parties and to request that we stop sharing your personal information with third parties for the third parties’ direct marketing purposes.

If you would like to discuss or exercise such rights, please contact us through the contact information below. As part of submitting a request, we will ask for your name, email address, phone number, date of birth, and mailing address. We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights.

6 INTERNATIONAL TRANSFERS

We will ensure that any transfer of personal information to countries outside of the United States will take place pursuant to the appropriate safeguards.

7 AMENDMENTS TO THE PRIVACY POLICY

From time to time, we have the right to modify this Privacy Policy. You will always be able to consult the most recent version of the Privacy Policy on the website.