Privacy Policy

Created: 5/1/2020
Last Annual Review: 6/2/2023

At Viewgol, we take your privacy seriously. Please read the following to learn how we treat your personal information.

This Privacy Policy describes the policies and procedures of Viewgol LLC and its affiliates (“Viewgol”, “we”, “our” or “us”) on the collection, use, and disclosure of personal information from those who use or access viewgol.com, our branded pages on social media services, or any of the other sites, services, features, promotions, credits, content, applications and/or products we offer in the United States and abroad (collectively, the “Services”). By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, you agree to be bound by all of its terms and conditions, and you consent that we will collect, use, and share your information in the following ways. If you do not agree to these terms, please do not access or use this site.

If you have a disability and are having trouble accessing this Privacy Policy, please contact us by email at legal@viewgol.com.

Changes to Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Such changes, modifications, additions, or deletions will be effective immediately upon notice, which may be given by means including, but not limited to sending an email to the email address listed by users and posting the revised Privacy Policy on this page. You acknowledge and agree that it is your responsibility to maintain a valid email address as a user and to review this site and this Privacy Policy periodically to be aware of any modifications. If you opt not to receive legal notice emails from us (or you have not provided us with your email address), our legal notices will still govern your use of the site, and you are still responsible for reading and understanding them. Your continued use of the site after such modifications will constitute your acknowledgment of the modified Privacy Policy, and your agreement to abide by and be bound by the modified Privacy Policy.

Children Under the Age of 18

We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information through Viewgol or through any features of the Services, register on this website, make any purchases through this website, use any of the interactive or public comment features of this website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a minor without verification of parental consent, we will delete that information. If you believe we might have any information from or about a minor, please contact us at legal@viewgol.com.

California residents 16 years of age or younger may have additional rights regarding the collection and sale of their personal information. Please see User Choices on Collection and Use of Information (below) for more information.

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “Personally Identifiable Information” and “Nonpersonally Identifiable Information” under applicable data privacy laws, rules, or regulations. Our primary goal in collecting information from you is to provide you with a smooth, efficient, and customized experience while using our site. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage, and applies only to Personal Data that we collect from you directly.

Personally Identifiable Information: This refers to information that lets us know the specifics of who you are. When you engage in certain activities on this site, such as registering for a membership, ordering a product or service, submitting content and/or posting content in discussion forums or other public areas, entering a contest or sweepstakes, filling out a survey, or sending us feedback, we may ask you to provide certain information about yourself by filling out and submitting an online form. It is completely optional for you to engage in these activities. If you elect to engage in these activities, however, we may ask that you provide us personal information, such as your first and last name, mailing address (including zip code), email address, employer, job title and department, telephone and facsimile numbers, and other personal identifying information. When ordering products or services on the site, you may also be asked to provide a credit card number. Depending on the activity, some of the information we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.
Nonpersonally Identifiable Information: This refers to information that does not by itself identify a specific individual. We gather certain information about you based upon where you visit on our site in several ways. This information is compiled and analyzed on both a personal and an aggregated basis. This information may include the Uniform Resource Locator (“URL”) of the website that you visited just prior to viewgol.com, which URL you next go to, what browser you are using, and your Internet Protocol (“IP”) address. A URL is the global address of documents and other resources on the World Wide Web. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol (“TCP/IP”) network, such as the World Wide Web. Networks like the Web use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the web, allowing web servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the Internet.

Collection Methods and Use of Personal Data

We do not collect any Personally Identifiable Information about you unless you voluntarily provide it to us. You provide certain Personally Identifiable Information to us when you: (a) register your email address with us; (b) voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires; (c) enter sweepstakes or contests sponsored by us or one of our partners; (d) sign up for special offers from selected third parties; (e) send us email messages or otherwise contact us; or (f) submit your credit card or other payment information when ordering and purchasing products and services on our site. We may also collect information from you at other points on our site that state that such information is being collected, through cookies (defined in further detail below), through your browser (if you use a location-enabled browser), or from third party service providers or advertising partners.

In addition, we may also collect, or our third-party ad server and/or content server may collect, certain Nonpersonally Identifiable Information. This information is ultimately stored in the form of store categories, and, in some cases, specific URLs. We use your IP address to diagnose problems with our servers, with our software, to administer our site, and to gather demographic information. Our third-party ad servers will also provide us with summary, but not individual, reports that will tell us how many ads were presented and clicked on at our site.

We will primarily use your Personal Data to provide our services to you, as required by our agreements with you. We will also use Personal Data to enhance the operation of our site, fill and process orders, improve our marketing and promotional efforts, statistically analyze site use, improve our product and service offerings, provide support and assistance for the Services, create and manage your Account or other user profiles, and customize our site’s content, layout, and services. We may use Personal Data to deliver information to you and to contact you regarding administrative notices. We may also use Personal Data to resolve disputes, protect against or deter fraudulent, illegal, or harmful actions and maintain the safety, security, and integrity of our Services, respond or comply with law enforcement requests and as required by applicable law, court order, or governmental regulation, troubleshoot problems and enforce our agreements with you, including our Terms of Use and this Private Policy, or for any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).

Categories of Personal Data We Collect

Category of Personal Data	Examples of Personal Data We Collect	Categories of Third Parties With Whom We May Share Some or All of this Personal Data:
Profile or Contact Data	· First and last name · Email · Phone number · Unique identifiers such as user names and passwords	· Service Providers · Advertising Partners · Analytics Partners · Parties You Authorize, Access, or Authenticate
Payment Data	· Payment card type · Last 4 digits of payment card · Billing address	· Service Providers (including, but not limited to, our payment processing partners)
Commercial Data	· Purchase history	· Purchase history · Service Providers · Advertising Partners · Analytics Partners · Parties You Authorize, Access, or Authenticate
Device/IP Data	· IP address · Device ID · Domain server · Type of device/operating system/browser used to access the Services	· Service Providers · Advertising Partners · Analytics Partners · Parties You Authorize, Access, or Authenticate
Web Analytics	· Web page interactions · Referring webpage/source through which you accessed the Services · Non-identifiable request IDs · Statistics associated with the interaction between device or browser and the Services	· Service Providers · Advertising Partners · Analytics Partners · Parties You Authorize, Access, or Authenticate
Social Network Data (data you share or that is on your profile on a third party social network)	· Email · Phone number · User name · IP address · Device ID	· Service Providers · Advertising Partners · Analytics Partners · Parties You Authorize, Access, or Authenticate
Consumer Demographic Data	· Age · Zip code	· Service Providers · Advertising Partners · Analytics Partners · Parties You Authorize, Access, or Authenticate
Geolocation Data	· IP-address-based location information	· Service Providers · Advertising Partners · Analytics Partners · Parties You Authorize, Access, or Authenticate
Sensory Data	· Photos, videos or recordings of your environment posted publicly to social media services or shared directly with us by you	· Service Providers · Advertising Partners · Parties You Authorize, Access, or Authenticate
Inferences Drawn From Other Personal Data Collected	· Profiles reflecting user attributes · Profiles reflecting user behavior	· Service Providers · Advertising Partners · Business Partners · Parties You Authorize, Access, or Authenticate
Other Identifying Information that You Voluntarily Provide	· Identifying information in emails or letters you send us	· Service Providers · Parties You Authorize, Access, or Authenticate

How We Share Your Personal Data

We disclose your Personal Data to service providers and other parties for the following business purposes:

Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
Debugging to identify and repair errors that impair existing intended functionality
Short-term, transient use of Personal Data that is not used by another party to build a consumer profile or otherwise alter your consumer experience outside the current interaction
Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider
Undertaking internal research for technological development and demonstration
Undertaking activities to verify or maintain the quality or safety of a service or device that we own, manufacture, was manufactured for us, or control

We disclose your Personal Data to the following categories of service providers and other parties:

Service providers, including payment processors, shipping and logistics companies, name and address verification providers, ad networks, hosting and other technology and communications providers, analytics providers, marketing service providers, email distribution service providers, customer relationship management service providers, and staff augmentation and contract personnel
Parties who acquire your Personal Data through an acquisition or other change of control (Personal Data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business—in whole or in part)—should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices
Other parties at your direction, such as other users (where you post information publicly through the Services), social media services (if you intentionally interact with them through your use of the Services), or other parties authorized by you
Security and fraud prevention consultants and third-party business partners who you access through the Services

We will encourage our service partners to adopt and post privacy policies. However, the use of your Personal Data by our service partners is governed by the privacy policies of those service partners, and is not subject to our control.

Occasionally we may be required by law enforcement or judicial authorities to provide Personal Data to the appropriate governmental authorities. We will disclose Personally Identifiable Information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

Sales of Personal Data: In this section, we use the term ‘sell’ (and equivalents ‘sale’ or ‘sold’) as this term is defined in the CCPA. We have not sold your Personal Data for monetary consideration over the last 12 months. However, subject to your right to opt-out of the sale of your Personal Data as outlined in this Privacy Policy, we collect and share Personal Data with third party advertisers to allow us to analyze the effectiveness of ads and deliver ads that are more relevant to you, which such sharing of Personal Data may be considered a sale of Personal Data under the CCPA. Over the past twelve months, we have shared the following categories of your Personal Data to third party advertisers: Personal identifiers, device/IP data, web analytics, IP-address-based location information, contact data and/or social network data.

Updating and Correcting Information

We believe you should have the ability to access and edit the Personal Data that you provide us. You may change any of your Personal Data in your account online at any time by linking to your account in accordance with instructions posted elsewhere on this site. You may also access and correct your personal information and privacy preferences by writing us at:

Viewgol LLC
Attn: Privacy Compliance Officer
legal@viewgol.com

Please include your name, address, and email address when you contact us.

We encourage you to promptly update your Personal Data if it changes. You may ask to have the information on your account deleted or removed; however, because we keep track of past transactions, you cannot delete information associated with past transactions on this site. In addition, it may be impossible to completely delete your information without some residual information because of backups.

User Choices on Collection and Use of Information

We may, from time to time, send you email regarding our products and services. In addition, if you indicated upon registration that you are interested in receiving offers or information from us and our partners, we may occasionally send you direct mail about products and services that we feel may be of interest to you. Only Viewgol LLC (or agents working on behalf of Viewgol LLC and under confidentiality agreements) will send you these direct mailings and only if you have not indicated that you object to these offers. If you do not want to receive such mailings, simply tell us when you give us your personal information, or, you can easily edit your account information at any time to no longer receive such offers and mailings.

You also have choices with respect to cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies some parts of our site may not work properly in your case.

California residents may have additional personal information rights and choices:

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit the following link: https://oag.ca.gov/system/files/attachments/press_releases/CCPA%20Fact%20Sheet%20%2800000002%29.pdf

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to legal@viewgol.com.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use, and disclosure using appropriate physical, technical, organizational, and administrative security measures based on the type of Personal Data and how we are processing that data. All credit card information regularly collected through the Services is encrypted and maintained using industry standard methods designed to ensure its security against loss or theft, including during transmission to our third-party payment processors. Your financial information, such as your payment method (valid credit card number, type, expiration date, or other financial information) is used and stored by our payment processor, and use and storage of that information by the payment processor is governed by the payment processor’s applicable terms of service and privacy policy.

You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism, limiting access to your computer or device and browser, and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss, or inadvertent disclosure of your information or content.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Tracking Tools, Advertising and Opt-Out

Our Services may use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Services, to analyze trends, learn about our user base, and operate and improve our Services. Cookies are small pieces of data–usually text files–placed on your computer, tablet, phone, or similar device when you use that device to use our Services. We may also supplement the information we collect from you with information received from Third Parties, including Third Parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you and remember your preferences (for example, your choice of language or region).
Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services, what actions a visitor performs on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google, Inc. (“Google”) uses Cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at https://policies.google.com/technologies/ads or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your computer or device. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some of the Services and functionalities may not work. To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit www.allaboutcookies.org.

We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Internet-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research, and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit, or set their own Cookies on your browser, just as if you had requested a web page from their site.

We comply with the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based on a consumer’s online behavior across different websites and properties. To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt-out pages, which are located at www.networkadvertising.org/choices or www.aboutads.info/choices.

Privacy Policies of Third Party Sites

Except as otherwise discussed in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. Other sites accessible through our site have their own privacy policies and data collection, use and disclosure practices. Please consult each site’s privacy policy. We are not responsible for the policies or practices of third parties. Additionally, other companies which place advertising on our site may collect information about you when you view or click on their advertising through the use of cookies. We cannot control this collection of information. You should contact these advertisers directly if you have any questions about their use of the information that they collect.

Miscellaneous Privacy Issues

You should also be aware that when Personal Data is voluntarily disclosed in the discussion forums or other public areas on this site, that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control and this Policy does not apply to such information. Any submissions to chat rooms or other public areas on this site are accepted with the understanding that they are accessible to all third parties. If you do not want your comments to be viewed by third parties, you are advised not to make any submissions. Ultimately, you are solely responsible for maintaining the secrecy of your password and/or account information. Please be careful and responsible whenever you are online.

Contact Information

If you have any questions about this Privacy Policy, the practices of our Services, or your dealings with our Services, please contact us at legal@viewgol.com.