Verde Circle PRIVACY POLICY

Last Modified on September 29, 2015

Our Privacy Commitment

Verde Circle (“Verde Circle,” “we,” “us” or “our”) is committed to respecting the privacy rights and concerns of all users of the Verde Circle where this Privacy Policy is posted (the “Site”) (we refer to the Site, the services and the software made available by Verde Circle, including the mobile application (the “App”) collectively, as the “Verde Circle Features”). As such, we have established and implemented this Privacy Policy to inform visitors to the Site and users of the Verde Circle Features how we use and protect the information we collect through the Verde Circle Features. By visiting the Site or using any of the Verde Circle Features, you consent to Verde Circle’s collection, use, storage, deletion and disclosure of information relating to you as set forth in this Privacy Policy. This Privacy Policy is effective as of the date set forth above and is only applicable to the Verde Circle Features and not to any other website that you may be able to access from the Verde Circle Features which may have its own data collection and use practices and policies.

This policy answers the following questions:

  • What information do we collect about you and how do we use it?
  • Will we share your personal information with third parties?
  • What choices do you have about the collection and use of your personal information?
  • What security measures do we take to safeguard your personal information?

What information do we collect about you and how do we use it?

Types of Information We Collect

Personal information means information that can be used to identify and contact you. You need to submit personal information to access the Verde Circle Features. We may collect non-personal information such as your browser type, when you accessed the Site and from what physical location you accessed the Site. This information may be aggregated to measure the number of visits, average time spent, page views, and other statistics about users of the Site. We also may use this data to monitor the Site’s performance and to make the Site easier and more convenient to use.

We also collect personal information when you create an account through the Verde Circle Features; subscribe to our newsletter; participate in feedback forms; purchase a product through the Verde Circle Features; or receive customer or technical support.

To create an account for the Verde Circle Features, we require you to provide certain information to create your profile, including your name, email address, password, mailing address, and phone number. Providing additional information beyond what is required to create an account, such as a photo, age, birth date, gender, or income is entirely optional, but enables you to gain more from the Verde Circle Features. When you are purchasing products through the Verde Circle Features, you will also be required to provide a billing address and credit card or other payment information. No information of this type will be collected unless you have registered for services that require it.

If you sign up for one of our services which involves social networking sites, we may also collect personally identifiable information from these Internet sources and database services. Depending on your choices when using the Verde Circle Features, we may collect additional personal information. We also offer features of the Site that allow you to link your account to LinkedIn, Twitter, and Google+. If you sign up for one of these services, we may also collect personally identifiable information from these Internet sources and database services.

By submitting personal information through the Site, you authorize Verde Circle to share this personal information for the purposes identified herein and on the Site, such as responding to user inquiries processing transactions, distributing materials, and requesting feedback.

Third Party Privacy Policies

Through the Verde Circle Features, you may be able to link to technology, software and services owned and controlled by third parties (“Third Party Features”). You may be permitted or required to submit personal information to access Third Party Features. Such use of Third Party Features and submission of information through Third Party Features will be subject to such applicable third party’s Terms of Use/Service and Privacy Policy. You agree to look solely to the applicable third party and not to Verde Circle to enforce your rights in relation thereto. When you have clicked on a third party logo or URL displayed on the Site, or accessible through the Verde Circle Features, which links you to any Third Party Features, our ToU no longer applies and you must read the Terms of Use/Service and Privacy Policy of the third party to see how your personal information will be handled on their website.

How We Use Your Personal Information

The personal information you provide to us will allow us to fulfill your product or service order; verify your identity; alert you of new products or services, features, or enhancements; handle your customer service questions or issues; provide for order processing; request feedback; distribute newsletters; and notify you of promotions, updates, or special offers that we think may interest you. We may also use your email address as part of the Verde Circle Features in sending you messages about the Verde Circle Features and other general announcements. Additionally, personal information that you make public will be viewable by other users of the Site. We keep track of your interactions with us, including but not limited to your activity within the Verde Circle Features. We may also use your personal information to contact you when necessary. Except as set forth in this Privacy Policy, or unless we have your consent, we will not share your personal information with any person or entity other than those affiliated with Verde Circle, entities acting on behalf of Verde Circle, and relevant third parties such as those needed to collect and maintain our information collection servers and perform technology and related services.

We may use your personal information with non-personal information that we have collected in a manner such that the end-product does not personally identify you or any other user of the Verde Circle Features. We may make your personal information non-personally identifiable by either combining it with information about other users (aggregating your personal information with information about other users), or by removing characteristics (such as your name or email address) that make the information personally identifiable. This process is known as de-personalizing your information. You grant us a royalty-free, worldwide, perpetual, irrevocable and fully transferable right and license to use your personal information in connection with the creation and development of analytical and statistical analysis tools relating to the use of the customer data we collect in providing the Verde Circle Features (the “Analytical Data”). We are expressly authorized to make any commercial use of the Analytical Data, including without limitation, sharing the Analytical Data with third parties, provided that we do not sell, trade, or otherwise transfer from us any part of the Analytical Data that personally identifies any Verde Circle Features users.

Do Not Track

In compliance with California legislation, AB370, effective January 1, 2014, Verde Circle’s practices in responding to “do not track” signals and collecting user information over time and across a network of websites when you visit the Site are described below. We honor the request of “do not track” signals sent by your browser when you visit the Site. Otherwise, Verde Circle may collect user information about your online activities over time and across different websites, or authorize third parties to do so.

Google Analytics

The Site uses Google Analytics to help us learn about who visits the Site and what pages are being viewed.

Cookies

“Cookies” are small bits of electronic information that a website sends to a visitor’s browser and are stored on the visitor’s hard drive. Like many websites, we employ cookies in certain areas of the Site to allow us to provide information to make your online experience more convenient. For example, when you return to the Site after logging in, cookies provide information to the Site so that the Site will remember who you are on subsequent visits, speeding up or enhancing your experience of the Verde Circle Features by, for instance, tailoring content to you.

Third parties whose websites are accessible through links on the Site may also use their own cookies when you link to their site or service. Verde Circle does not control these third parties’ use of cookies and cannot guarantee that they will uphold the same privacy standards as Verde Circle. Verde Circle expressly disclaims any and all liability related to the collection, use or disclosure of information by third parties. You should review the privacy policies of any third party sites that you visit through a link on the Site to understand how these third parties use cookies and the information they collect through cookies. Most cookies are “session cookies” which means that they are automatically deleted at the end of each session. Most browsers are initially set to accept cookies. You can set your browser to notify you when you receive a cookie, giving you a chance to decide whether or not to accept it.

Log Information

Our servers automatically record information that your browser sends whenever you visit the Site. This information includes your Internet Protocol address, your browser type and version, the search engine you used to find the Verde Circle Features, if any, which Verde Circle Features you use and when and how long you use them. We use this information to monitor and analyze how users use the Verde Circle Features, to provide customer service and to maintain and improve the Verde Circle Features.

Children’s Privacy

We do not knowingly collect personal information from children under 13, or allow them to create an account for the Verde Circle Features. We take children’s privacy seriously, and encourage parents to play an active role in their children’s online experience at all times.

Will we share your personal information with third parties?

Sharing of Information

We use your personal information to complete transactions, respond to your requests, deliver products and services you request, and send communications to you about promotions, updates, or special offers (which may be offered by Verde Circle or one of its business partners) that may be of interest to you. We may share your personal information with carefully selected vendors and business partners, including companies that perform marketing services and other business operations for us. We may also use your personal information to provide analyses of our users in the aggregate (including Analytical Data subject to the terms of this Privacy Policy) to prospective partners and other third parties. In addition, we will share the personal information we collect from you under the following circumstances:

  • Protection of rights. We will share personal information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is appropriate to enforce our Terms of Use for the Verde Circle Features, including any investigation of potential violations thereof, (iii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Verde Circle Features, or (iv) such action is appropriate to protect the rights, property or safety of Verde Circle, its employees, users of the Verde Circle Features or others.
  • Asset transfers. If we become involved in a merger, acquisition or other transaction involving the sale of some or all of Verde Circle’s assets, user information, including personal information collected from you through your use of the Verde Circle Features, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you through email and/or a prominent notice on the App and/or Site.
  • Service Providers. We may share your personal information with service providers (including our affiliates that provide services on our behalf) that we engage for the purpose of processing information on our and your behalf. For example, we may partner with other companies to process payments for the Verde Circle Features. Additionally, we may partner with other companies to process, analyze, and/or store data, including, but not limited to, Analytical Data. While providing services for us, these companies may access your personal information. To the extent applicable, we require these entities to comply with this Privacy Policy and appropriate confidentiality and security measures.

Additional Information You Should Know About Third Parties

The Site may contain direct links to websites operated by our partners and other entities, including links that describe certain Verde Circle Features being “powered by” the companies providing services in connection with such Verde Circle Features. These third party websites may collect information about you when you visit them or otherwise communicate with them. This Privacy Policy does not cover the information practices of third party websites linked to the Site or accessible through the Verde Circle Features. Although we encourage such third parties to adopt and follow their own privacy policies, we are not responsible for their collection and use of your personal information. You should refer to the privacy policies and statements of other websites or contact the respective webmasters of those websites to obtain information regarding their information collection, use and disclosure policies.

What choices do you have about the collection and use of your personal information?

Control of Your Information

You may update or delete your personal information or modify your account preferences for the Verde Circle Features by accessing the account interface provided through the Verde Circle Features. Please note that if you delete your account, we will keep your email address and submitted content on file and may retain your account information for a reasonable period of time afterward for the purpose of internal account management and fraud prevention activities.

Opting Out of Receiving Communications from Us

If you no longer want to receive our newsletter, emails or other announcements, you may unsubscribe by selecting “unsubscribe” in your account or replying to the unsubscribe link at the bottom of our emails. Please note that you cannot unsubscribe from certain correspondence from us, including messages relating to your account transactions.

Mediation

If you are a resident of a country outside of the European Union, you also agree that, in the event any dispute or claim arises out of or relating to this Privacy Policy that you and Verde Circle will attempt in good faith to negotiate a written resolution of the matter directly between the parties. You agree that if the matter remains unresolved for forty-five (45) days after notification (via certified mail or personal delivery) that a dispute exists, all parties shall join in mediation services in Los Angeles, California with a mutually agreed mediator in an attempt to resolve the dispute. Should you file any arbitration claims, or any administrative or legal actions without first having attempted to resolve the matter by mediation, then you agree that you will not be entitled to recover attorneys’ fees, even if you would otherwise be entitled to them.

Dispute Resolution for Residents of the European Union

If you are a resident of the European Union, in the event that you have any dispute or claim arising out of or relating to this Privacy Policy, you may report your claim to the European Union Data Protection Authorities located in your jurisdiction.

What security measures do we take to safeguard your personal information?

The personal information that you provide to us is stored on servers, which are located in secured facilities with restricted access, and protected by protocols and procedures designed to ensure the security of such information. In addition, we restrict access to personal information to Verde Circle employees, independent contractors and agents who need to know this information in order to develop, operate and maintain the Verde Circle Features. All Verde Circle personnel who have access to this information are trained in the maintenance and security of such information. However, no server, computer or communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect user information, we cannot ensure or warrant the security of any information you transmit to us or through the use of any of the Verde Circle Features and you acknowledge and agree that you provide such information and engage in such transmissions at your own risk. Once we receive a transmission from you, we will endeavor to maintain its security on our systems.

In the event that personal information you provide to us is compromised as a result of a breach of security, when appropriate we will take reasonable steps to investigate the situation, notify you and take the necessary steps to comply with any applicable laws and regulations.

Notification of Changes

This Privacy Policy may change from time to time and we will post all changes on this page.

Questions? Contact Us

If you have any questions about our privacy practices or this Privacy Policy, please contact us by email at jennifer @ verdecircle.com.

Terms of Use

Please read the Terms of Use governing the use of the Site.