Your privacy is important to us, and we are committed to fair practices that protect your information. This "Privacy Policy" applies to www.villagers.co (the "Site") and our retail consumer analytics and communications and marketing platform (the "Software," and together with the Site, the "Platform"), which are owned and operated by Villagers IRL, Inc. ("we," "us," or "our"). This Privacy Policy explains how we collect, use, and disclose personally identifying information ("Personal Information") gathered through the Site and Platform.
For clarity, this policy uses the following definitions:
We collect and process:
We may collect (or receive) from Local business and process on Local business' behalf:
We may use End Customer and Visitor information to:
Additionally, we may share information:
We do not own, or claim ownership of, Local business information or End Customer information. Ownership of such information and usage rights with respect thereto are governed by our agreements with the Local business or the End Customer, as applicable, under which such information is made available to us.
If and to the extent authorized by an End Customer in connection with its agreement with a Local business, such Local business can deliver email and text messages to such End Customer via the Platform.
Local Business may send individual 1:1 direct messages to their End Customers such as:
Local Business may send individual service-related messages to their End Customers such as:
Local Business may send promotional messages through the Platform such as:
For purposes of the Platform, Local Business are required to warrant that each End Customer:
Each End Customer's agreement with its Local business is specific to such individual End Customer's relationship with the Local business. If an End Customer does not believe it authorized a Local business to provide us with any of the foregoing authorization, such End Customer should contact us using the contact information set forth below. If an End Customer desires to update its permissions with one of our Local Business, such End Customer should contact such Local business directly (as each Local business is responsible for this data and these permissions).
Please note we will be unable to process most of your requests immediately but will endeavor to do so as promptly as commercially practicable.
Our Software uses or may in the future use artificial intelligence and machine learning modules to analyze Personal Information in aggregate, anonymized, and blinded formats. Using artificial intelligence and machine learning modules or other tools, we may aggregate, anonymize, and/or de-identify Personal Information for the purposes of:
We will not make any attempts to reidentify information that has been anonymized and/or de-identified. Data generated by the Software is owned by us.
We may use third party vendors to:
We are not responsible for the information practices of third parties. Any access to use of third party links on the Site or in the Platform are governed by such third party's privacy policy and we are not responsible for any acts or omissions of such third party.
Except to the extent set forth herein, these third parties are prohibited from using your Personal Information and we exercise commercially reasonable efforts to ensure they contractually agree to treat your Personal Information as confidential.
We collect information through our servers and filtering systems when you visit our website. Cookies are small text files placed on your computer that collect standard internet log information and track website activities.
We may use cookies to:
Information we collect:
Cookie Management: You control cookie settings through your browser. Not accepting cookies impacts some Platform features. Learn more at http://www.allaboutcookies.org.
Web beacons are tiny graphics, similar in function to cookies, that track the online movements of users. They are not stored on your computer and may not be disabled or controlled through your browser.
We store Personal Information behind secured networks that are only accessible by a limited number of our personnel who have special access rights to such systems and are required to keep the Personal Information confidential. We implement a variety of security measures when you access the Platform to maintain the safety of your Personal Information. While these measures are helpful to safeguard Personal Information, we cannot guarantee the security of Personal Information submitted to us.
In the event Personal Information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and will notify such End Customer, as appropriate, in accordance with the applicable laws and regulations.
We will only maintain Personal Information for as long as necessary for delivering and maintaining the Platform. We may retain your questions and feedback in order to improve the Platform. Do not send us any information, ideas, suggestions, proposals or comments that you consider confidential or that you wish to be treated as confidential. If you no longer want us to use or retain the Personal Information you provided to us, you may contact us at irl@villagers.co and request that we delete your Personal Information from our records. We will honor your Personal Information deletion requests except with respect to information we may be required by law to retain.
If deletion is not possible, we will de-identify your Personal Information in a manner that cannot be reversed. If de-identification is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
If you provide Personal Information to us, we may transfer, process, use, or store such Personal Information in a country other than the country in which it was collected, including the United States or other destinations outside the EEA (as defined below). Do not provide Personal Information to us if you do not consent to that information being transferred outside of the EEA. Your Personal Information may be transferred to countries that have been deemed to provide an adequate level of protection for Personal Information by the European Commission.
Where there is no adequacy decision by the European Commission in respect of a country (to the extent that they are outside of the EEA), which means it is not deemed to provide the adequate level of protection for your Personal Information, we will ensure your Personal Information receives an adequate level of protection. For example, each such transfer to a third party will be protected by contractual commitments and further assurances (where appropriate) such as the European Commission's approved Standard Contractual Clauses.
For additional information on the mechanisms used to protect your Personal Information, please contact us via email at irl@villagers.co.
Under California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and related privacy laws, California residents have specific rights regarding Personal Information. We comply with these laws by:
Under California's "Shine the Light" law (California Civil Code Section 1798.3), you can request a summary of our annual disclosures to third parties of your Personal Information for direct marketing purposes. To obtain this information, please email us at irl@villagers.co and place "Shine the Light Request" in the subject line. Please be aware that not all information sharing is covered by "Shine the Light" requirements and only information on covered sharing will be provided.
Per California Civil Code Section 1789.3, California residents can contact the Complaint Assistance Unit of the Division of Consumer Services, California Department of Consumer Affairs:
To exercise your rights, email us at irl@villagers.co. We will:
The Children's Online Privacy Protection Act (COPPA) and COPPA Rule, enforced by the Federal Trade Commission, protect children's online privacy by:
Our Platform:
Under the General Data Protection Regulation (GDPR), European Economic Area ("EEA") Visitors and End Customers are "Data Subjects" with specific rights. We process personal data under these legal bases:
If you are located in the EEA and have questions or concerns about our data processing practices and procedures, please contact us at irl@villagers.co.
We update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. Changes to this Privacy Policy will be effective upon publication to the Site.
If you have questions about this Privacy Policy or our privacy practices, please contact us at: