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Victors & Spoils

Privacy Policy

This Victors & SpoilsPrivacy Policy (“Policy”) describes the practices Victors & Spoils (“V&S,” “we,” or “us”) observes when using and sharing data and other information (“Information”) collected through:

The V&S websites located at www.victorsandspoils.com, www.pearlstreetmarketplace.com, and any other websites operated by V&S (our “Sites”);

The services and other functionality we provide through our Sites (our “Services,” and together with the Sites and Apps, our “Platform”).

By using any part of the V&S Platform you consent to the collection and use of your Information by or on behalf of V&S as described in this Policy.

If you have any questions or concerns regarding this Policy or the Information collection or usage practices applicable to the Platform under this Policy, please contact us at howdy@victorsandspoils.com.

If we need, or are required, to contact you concerning any event that involves this Policy or your Information we may do so using the email address, telephone number, or physical mail address we have on file for you.

Summary.

Although we encourage you to read the entire Policy, the following provides a summary of some of the important aspects of this Policy:

  • This Policy is applicable only to Information collected through the Platform. This Policy does not apply to Information collected by third parties outside of the Platform.
  • We may collect both Non-Personal Information and Personal Information from you through the Platform.
  • We may obtain Sensitive Personal Information from you through the Platform.
  • We will not use or share your Personal Information (including Sensitive Information) except as permitted by this Policy.
  • You are permitted to “opt out” of certain uses of your Personal Information.
  • We will take reasonable and appropriate measures to secure your Personal Information, but we make no promise that your Personal Information will remain secure in all circumstances.

Scope of this Policy.

The Platform enables you and other users of the Platform (“Users”) to interact both with V&S through the platform and with each other and other third parties through the Platform as well. When you use the Platform to interact with other Users and third parties, you may share your Information with those other Users and third parties. You consent to V&S facilitating the sharing of your Information with those other Users and third parties as you direct through the Platform in accordance with this Policy.

You also agree that this Policy covers only the use and sharing of Information collected by and on behalf of V&S. V&S is not responsible for the privacy practices of other Users or third parties you interact with through the Platform (or outside the Platform) and THIS POLICY DOES NOT COVER THE COLLECTION OR USE OF INFORMATION BY ANY OTHER USER OR THIRD PARTY YOU INTERACT WITH THROUGH THE PLATFORM OR OUTSIDE OF THE PLATFORM. For information about what separate terms may apply to the Information you share with any other User or third party, please contact the User or third party before sharing Your Information.

Information We Collect Through the Platform.

The Information we collect about you through the Platform includes both “non-personal” and “personal” Information. We may also obtain “sensitive” personal information about you through the Platform. For purposes of this Policy:

Non-Personal Information” refers to information that may not by itself be reasonably associated with, linked to, or used to identify you. For example non user-specific Information regarding your use of the Platform or the operation of the Platform, including your domain name, Internet Protocol (IP) address, or browser type or settings. Non-Personal Information will also include any non user-specific Information we may derive from this Information.

Personal Information” refers to information that may be reasonably associated with, linked to, or used to identify you or allow you to be personally identified or contacted. For example, Personal Information may include information such as your first and last name, business name, professional information, gender, age, email address, telephone number, street address, social media accounts, and other Information or content you may provide to us in response to our questions on the Platform, such as annual income or marital status, either alone or in combination with other Information.

Sensitive Personal Information” refers to Personal Information regarding more sensitive areas such as your credit card or other financial information, precise geolocation information, or medical or health information.

Sources of Information.

We may collect Information about you through the Platform from a variety of sources, for example:

Directly from You. We may collect Information about you directly from you when you voluntarily provide it to us through the Platform. For example, through registering for an account on , responding to a survey or other request, entering a contest or promotion, communicating with V&S, or communicating with other Users through the Platform. We may use any Information you provide through your use of the Platform in accordance with this Policy.

From Other Users. We may collect Information about you from other Users when they provide Information through the Platform. For example, when they communicate with you through the Platform or store information about you on the Platform. We may use any Information other Users provide through the Platform in accordance with this Policy.

From Our Third Party Vendors. We may obtain Information about you from the third party vendors that provide services to us. For example, if we use a third party vendor to facilitate registration for the Platform, and you register for the Platform using that third party vendor’s services, we may receive Information about you from that third-party. We may use any Information that we obtain from our third party vendors in accordance with this Policy.

From Other Third Parties. We may also obtain Information about you from other third parties that have obtained or collected Information about you and that have the right to provide that Information to us. For example, we may contract with third parties that collect and aggregate information regarding people generally to receive the information they hold about you. We may use any Personal Information about you we obtain from these third parties in accordance with the terms we establish with those third parties. If we combine that Personal Information with Information we collect from you under this Policy, then we will use that Personal Information in accordance with this Policy as well.

Through the Operation of the Platform. We may collect Information about you automatically when you interact with the Platform. For example, V&S and our third party advertisers and service providers may use “cookies,” “web beacons,” and other automated tracking technology to monitor and collect Information regarding how you access, use, and interact with the Platform. “Cookies” are commonly used small files that are stored on your computer or mobile device to help identify you as a unique user of the Platform. “Web beacons” (also known as “single–pixel” or “clear” GIFs) include electronic images imbedded in the Platform that allow us to recognize when you visit that area of the Platform.

V&S and our third party advertisers and service providers may use cookies, web beacons, and other tracking technology that expire once you close your browser or log out of the Platform. We may also use technologies that persist and stay on your computer until you delete them. Most browsers will allow you to erase cookies from your computer or mobile device, block acceptance of cookies, or receive a warning before a cookie is stored. You may also be able to refuse certain web beacons by adjusting the settings on your browser or email software. Please refer to your browser or email software instructions or help screen to learn more about these functions.

The computers we use to provide the Platform may also automatically record Information about you. For example, our web servers may record the Information you enter on the Platform, the areas of the Platform you visit, the services you use through the Platform, your IP address, or cookies that are set on your browser. We may use any Information we collect from you automatically through the Platform in accordance with this Policy.

Please note that our third party advertisers and providers also use cookies, web beacons, or other tracking technologies in advertisements and other messages displayed on or communicated through the Platform. We do not have access to information that would confirm all uses of cookies, web beacons, or other tracking technology by our third party advertisers and providers.

How We Use Information.

Non-Personal Information. We may use and share the Non-Personal Information we collect through the Platform for any lawful business purpose without any duty or obligation of accounting or otherwise to you, provided that the Information remains Non-Personal Information. This will include, by way of example, providing Non-Personal Information to third parties or developing products, services, or other offerings based on Non-Personal Information or our analysis of Non-Personal Information.

Personal Information. We may use the Personal Information we collect about you through the Platform for a variety of purposes, for example:

  • Operating and providing services through the Platform;
  • Customizing and improving the Platform and Services for you;
  • Providing maintenance, support, updates, and customer services;
  • Providing notices, announcements and other communications to you;
  • Providing offers for products, services, or other offerings to you that we feel may be of interest to you;
  • Contacting you for direct marketing purposes regarding products, services and offerings;
  • Processing payments made through the Platform;
  • Developing additional products, services and offerings; and
  • Research and analysis purposes.

We may combine and enhance the Personal Information we collect about you through the Platform with Information we receive from third parties. We may also combine and enhance Personal Information using Non-Personal Information. In each case, we will treat the combined Information as Personal Information and use it in accordance with this Policy.

We may also use the Personal Information we collect about you through the Platform to generate Non-Personal Information. When we do so, we will take reasonable measures to ensure that the Non-Personal Information is no longer personally identifiable and may not later be reasonably associated with, linked to, or used to identify you. This will include, by way of example, storing the Non-Personal Information separately from any Personal Information. Once we generate Non-Personal Information from any Personal Information, we will not attempt to make that Information into Personal Information (i.e., to make it personally identifiable). However, we may combine and enhance that Non-Personal Information with other Non-Personal Information (including Non-Personal Information we obtain third parties) and use the Non-Personal Information in accordance with this Policy.

You should not provide any personal information through the Platform unless you agree to the use of that information in accordance with this Policy.

Sensitive Personal Information. V&S may receive Sensitive Personal Information from you when you agree to provide it to us through the operation of the Platform. For example, when you provide us with credit card or other financial information or choose to share other Sensitive Personal Information in communications with us. V&S will use any Sensitive Personal Information about you that we receive through the Platform solely in accordance with this Policy to enable the operation of the Platform and the exchange of that Information as directed by you. Note though that V&S is not responsible for monitoring the Sensitive Personal Information you choose to exchange with other Users or third parties through the Platform or for the use of that Information by those other Users or third parties.

How We Share Information.

We may share Information about you in a variety of ways, for example:

Affiliates and Subsidiaries. We may share Information with our affiliates and subsidiaries, including companies that we own or control, that own or control us, or that are under common ownership or control with us. We will require that our affiliates and subsidiaries agree to use the Information we share with them in compliance with this Policy.

Users. We may share Information with other Users when you decide to communicate with those Users (or request that we communicate on your behalf) through the Platform. This may include facilitating communications with other Users or enabling posting of Information to areas of the Platform accessible by other Users.

Business Partners. We may share Information with business partners for which we collect Information through the Platform. We will work with our business partners to provide notice concerning the purpose for which any Personal Information is being collected on behalf of any partner. Unless we otherwise notify you, any information we collect on behalf of a business partner will be in accordance with this Policy.

Service Providers. We may share Information we collect about you with third parties that help us provide any portion of the Platform. For example, we may use third parties to: (a) design, develop, host, maintain, or manage the Platform; (b) assist us with providing emails or other communications to you; (c) collect or analyze Information through the Platform; (d) customize or assist us in managing our databases; (e) develop or offer additional products, services or offerings to you; or (f) provide other services to us relating to the Platform on an outsourced basis, for example, payment processing or identity validation. We require that these third parties agree to use the Information we share with them only to perform their obligations to us and to treat all Personal Information they receive from us in compliance with this Policy.

Law Enforcement. We may share Information with law enforcement agencies if we reasonably believe unlawful activities have occurred or the Information may aid in an investigation into unlawful activity. We may also share Information with law enforcement if we determine, in our sole judgment, that you have violated our agreements or policies or that the release of your Information may protect the rights, property, interests, or safety of V&S or any third party.

Legal Processes. We may share Information as required by, or permitted by, law, whether in response to subpoenas, court orders, other legal processes, or as we believe is necessary to exercise our legal rights, including to defend against legal claims that have been or might be brought against us.

Business Transactions. If we transfer ownership or control of any portion of V&S or the Platform to a third party, whether or not in the context of an acquisition, merger, or reorganization, we may transfer Information that third party, provided that the use of any of your Personal Information by that third party remains subject to the terms of this Policy.

Choice and Opt-out.

We provide you with a choice whether to receive certain messages through the Platform and from V&S. We also may give you the opportunity to “opt-out” of having your Personal Information shared for certain purposes permitted by this Policy.

If you no longer wish to receive certain messages from V&S or to have your Personal Information shared by V&S in the manner permitted by this Policy, you may seek to opt-out of receiving those messages or having your Personal Information shared in that manner. In some cases, opting out of receiving messages or having your Personal Information shared will not affect your ability to use the Platform. However, some messages are necessary to the operation of the Platform. Likewise, some sharing of Personal Information is necessary to provide you the Platform. If you wish to opt-out of receiving these messages or of sharing your Personal Information in this manner, V&S may be required to limit or cancel your access to the Platform.

All opt-out requests made to V&S can be made as indicated through the Platform or contacting V&S as described above. Note that it may take up to 10 business days for V&S to remove contact information from our lists, so messages from us may continue for a time after a removal request is made.

Security.

V&S understands that the security of your Personal Information is important and is committed to protect and secure your Personal Information. Despite our commitment, no security system can be 100% effective and we cannot guarantee that your Information will be secure in all situations. We will nonetheless take all reasonable and appropriate steps to insure the safety and security of your Personal Information. This includes using industry standard security measures to protect the loss, misuse, and unintended alteration of the Personal Information under our control. For example, our policy is that only those individuals who need your Personal Information to perform a specific job for us are granted access to that Personal Information. Likewise, all employees and contractors are kept up-to-date on our security and privacy practices. Finally, the servers that we store personally identifiable information on are kept in a secure environment.

Advertising.

At present, V&S does not display advertising from third party advertisers through the Platform. If this changes, we will modify this Policy in accordance with the “Notification of Changes” section below.

Additional Terms.

Children. The Platform is not directed to children under 13 years of age. V&S does not knowingly solicit or collect personal information from children under 13 years of age.

Direct Marketing. California law provides that California residents have a right to request that businesses tell them how their personal information has been shared with third parties for use in direct marketing purposes. There is an exception to this requirement for businesses that have adopted and disclosed, in their privacy policy, a policy of not disclosing a person’s Personal Information to third parties for use in direct marketing purposes if that person has exercised an option to opt-out of the disclosure of their Personal Information to third parties for such purposes. We have adopted a policy of allowing you to opt-out of the disclosure of your Personal Information to third parties for direct marketing purposes and thus fall within this exception. Instructions for opting out can be found in the section of this Policy entitled “Choice and Opt-Out.”

Do Not Track. Certain web browsers and other devices you may use to access the Platform may permit you to indicate your preference that you do not wish to be “tracked” online. At this time we do not modify your experience on the Site or the Platform, or the Information we collect from you through the Site or Platform, based on whether such a preference is indicated.

Notification of Changes. We may notify you of any changes to this Policy by way of an email or by posting on the Platform. Changes to this Policy will be effective 30 days following such notice. Your continued use of the Platform after any change has become effective will constitute your acceptance of that change. Unless we seek and receive consent from you, we will use the Personal Information about you we collect through the Platform in accordance with the version of this Policy effective when the Personal Information was last collected.

Review and Update of Information. While V&S takes reasonable steps to ensure that the Personal Information we collect from you through the Platform is reliable for its intended use, accurate, complete, and current, we rely on you to update and correct your Personal information. Please contact us as described above to review, update, or change any of your Personal information collected through the Platform.