Last modified: December 20, 2023
Introduction
Clarkson Global, LLC d/b/a Velvet Llama ("Company" or "We") respects your privacy and are committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide when you visit the website www.velvetllama.com (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
- On this Website.
- In email, text, and other electronic messages between you and this Website.
- Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
- When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
It does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by Company or any third party; or
- Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Website.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
Access to Alcohol Products and Sites Restricted to Individuals of Legal Drinking Age
Company alcohol product sites and advertising are intended only for persons of legal drinking age based on the jurisdiction where such content is being accessed or viewed. You will be required to verify your date of birth prior to entering or interacting with a site. Age verification prompts may also be located within the sites.
We do not knowingly collect personal information from those under the legal drinking for those sites or products. If you are under the legal drinking age in your jurisdiction and have entered our site by providing a false date of birth, you must immediately leave the site. If you believe someone under the legal drinking age has provided us with personal information by obtaining access in violation of this privacy policy, please contact us immediately so that we may remove this personal information.
Information We Collect About You and How We Collect It
We collect person information relating to you in a variety of ways depending on how you interact with us.
A. Types of Personal Information We Collect. The following represents a non-exhaustive list of common activities with examples of the type of personal information that we collect and how we use that information:
| Context | Type of Personal Information (Examples) | Primary Purpose for Collection & Use |
|---|---|---|
| Contact customer service, make inquiries, or otherwise communicate with us | Contact information (e.g., name, address, email address, and phone number). Some of our Websites utilize live or automated conversation systems, or “chat bots,” that allow us to interact with customer, help customers buy goods and services, and answer a wide variety of questions. When you communicate with our chat bots, we collect the content that you send to us in order to reply. |
We have a legitimate interest in receiving, and responding to your inquiries and acting upon your feedback or issues. |
| Promotional communications | Contact information (e.g., name, address, email address, and phone number); | We share personal information about new products, events, and promotions with individuals as permitted by law. We also have a legitimate interest in sharing information about our products or services, and we may share information when you engage in a transaction or with your consent depending on the situation. |
| Order merchandise | Contact information (e.g., name, address, email address and phone number); Billing and shipping information (e.g., billing information such as credit card information, which is collected directly by our payment processor and shipping addresses and contact information). |
We use your information to perform our contract to fulfill your order and process your transactions/payments. |
| Register for an account | Contact information (e.g., name, address, email address, and phone number); Username and passwords used to access Websites. Verification or tokens through social media platforms. |
We have a legitimate interest in administering your account and providing account related functionalities. Accounts can be used for easy checkout and to save your preferences and transaction history. |
| Interact with us on social media | Social media information (e.g., profile name, profile image, and other images that you make available such as user-generated content). | We have a legitimate interest providing customers with a means for interacting with us on social media. |
| Enter a promotion, sweepstakes, contest, or other special offer | Contact information (e.g., name, address, email address, t age, and phone number); Government identification numbers (which may include, if you are resident in the US, Social Security Number (in limited circumstances, for example if you win a sweepstakes or receive compensation that must be reported on government tax forms)). |
We have a legitimate interest in operating the sweepstakes, contests, and special offers, including notifying you if you are selected. In some contexts we are also required by law or regulation to collect personal information about those that enter into our sweepstakes, and use that personal information in order to comply with those laws and regulations. |
| Complete a survey or voluntarily provide personal information about yourself | Demographic information including date of birth, gender, interests, state, zip/postal code Preferences, shopping habits, and other lifestyle information, including product wish lists, order history, marketing preferences, and cell phone carrier. | We have a legitimate interest in understanding our users and providing tailored services. We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. |
| Interact with our Site, emails, and/or online advertisements | Search queries, Application usage data; Server log file location, internet service provider, unique identifiers, user agents, or IP address; Personal information collected through cookies, tags, pixels, clear pixels, beacons, and other similar technologies; Referring and exiting websites/URLs (including click through URL and pixel tags); Browser and device information (including platform and version); | We have a legitimate interest in ensuring that our Site and services function correctly and without errors. Where we collect personal information through the deployment of cookies and other similar technologies on our Site in order to better understanding our users and providing tailored services, we will rely on your consent to do so or you may opt-out of such use depending on your jurisdiction. We will rely on your consent where we use personal information to understand how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We have a legitimate interest in monitoring our networks and the visitors to our Sites. We also have a legitimate interest in detecting and preventing fraud. |
Although the above chart describes examples of personal information we collect and our primary purpose in collecting such personal information, in many situations we have more than one legitimate purpose. For example, if you complete an online order, we collect your payment (directly through our payment processor) and shipping information to perform our contract with you (e.g., to process and fulfill your order), but we also collect your personal information because we have a legitimate interest in maintaining your personal information after your transaction is complete so that we can quickly and easily respond to any questions about your order. As a result, our collection and processing of your personal information is based in different contexts upon: (i) your consent (e.g., for marketing you have opted-in to receive, where required), (ii) the performance of our contract with you (e.g., to provide you with products and services you have requested); (iii) compliance with legal obligations (e.g., where we are required to disclose information to a court or tax authority); and/or (iv) our legitimate interests in conducting our business.
To the extent that any information is considered “personal information” by local law, we treat this information as such and ensure that our handling of this personal information complies with all applicable data privacy and protection laws. To the extent permitted by applicable law, any information you provide to us directly may be combined with other information that you provide to us through other channels, that is publicly available, or that we may otherwise obtain, including from third parties.
B. How We May Collect Personal Information. We collect personal information from various sources, including, for example the following:
- From You
- Out Sites Applications
- Offline
- Online tracking technologies, including cross-device tracking
- Mobile usage
- Through your browser or device;
- Through website analytics and advertising features; and
- Other sources
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Click here [URL LINK TO DO NOT TRACK DISCLOSURES] for information on how you can opt out of behavioral tracking on this website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
The information we collect automatically may include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. For information about managing your privacy and security settings for cookies, see Choices About How We Use and Disclose Your Information.
- Web Beacons. Pages of our Website [and our emails] may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We do not collect personal information automatically, but we may tie non-personal information collected automatically to personal information about you that we collect from other sources or that you provide to us.
Third-Party Use of Cookies [and Other Tracking Technologies
Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies [alone or in conjunction with web beacons or other tracking technologies] to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Website and its contents to you.
- To provide you with information, products, or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To provide you with notices about your account, including expiration and renewal notices.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our Website or any products or services we offer or provide though it.
- To allow you to participate in interactive features on our Website.
- For any other purpose with your consent.
We may also use your information to contact you about our own and third-parties goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see Choices About How We Use and Disclose Your Information.
We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Disclosure of Your Information
We may disclose aggregated information about our users without restriction.
We may disclose personal information that we collect or you provide as described in this privacy policy:
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Clarkson Global, LLC d/b/a Velvet Llama's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Clarkson Global, LLC d/b/a Velvet Llama about our Website users is among the assets transferred.
- To third parties to market their products or services to you if you have not opted out of these disclosures. For more information, see Choices About How We Use and Disclose Your Information.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Clarkson Global, LLC d/b/a Velvet Llama, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
- Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by emailing us at info@velvetllama.com.
- Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own or third parties' products or services, you can opt-out by sending us an email stating your request to info@velvetllama.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
- Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by sending us an email stating your request to info@velvetllama.com. For this opt-out to function, you must have your browser set to accept all browser cookies.
We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
Accessing and Correcting Your Information
You can review and change your personal information by logging into the Website and visiting your account profile page.
You may also send us an email at info@velvetllama.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use
Data Security
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Changes to Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by email to the email address specified in your account or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.
Contact Information
To ask questions or comment about this privacy policy and our privacy practices, contact us at:
