What Information Do We Collect?
Non-Personally Identifiable Information
When you sign up for your Account or use our Services (either on your mobile phone/device through the Application or though other devices or through the website), our servers may (i) automatically record information that your mobile phone/device sends or transmits, including your device type, your device ID number (for example, your UDID), user settings, your geographical location (if you consent to that) (for example, when you walk-in to a location if you are using the application on mobile phone) and information about your use of the Services such as offers viewed and/or used, new arrivals viewed and/or scanned and/or purchased and/or pictures shared via Vito, reviews and feedback viewed and/or created and/or shared, surveys taken, stores visited, information you entered, (ii) record which search terms you used, or which referring/exit pages brought you to our page, and date/time information, (iii) record certain non-personally identifying information record provided by you, such as your gender or date of birth, and (iv) record information derived from such above information and other sources such as entries and offers viewed on our website or on our social media presence, or information provided by Merchants (collectively, “Non-Personally Identifiable Information”).
Personal Information You May Provide To Us
When you use our Services, we may ask that you provide us with some personally identifiable information-information about you that can be used to contact or identify you, and information on your use or potential use of the Services and related services (“Personal Information”). Personal Information that we might collect may include things like your name, mobile phone number, other phone numbers, email address, home address, and, if you elect to share this information with us, store loyalty card numbers for our Merchants (as defined below) stores and other stores. Personal Information may also include other information you supply to us concerning your preferences and interests expressed in the course of using the Services.
Information About You We May Obtain Through Other Sources
We may also use additional methods to collect your Personal Information when you are physically visiting the store of one of our Merchant Partners, such as by using barcode scanning and walk-in and location data gleaned from your mobile device. If you do not wish to have your Personal Information collected by these methods, you may not be able to earn and redeem rewards as part of the Services.
We may also receive Personal Information from Merchants provided by you in the course of your using their services, or from third parties (e.g., white pages listings providers), subject to the limitations of the Privacy Policies of those Merchants or third parties.
Information About Transactions at Merchants
How Do We Use the Information?
The terms “using” and “processing” information, as used in this policy, include using cookies or other storage means on a computer or mobile device, subjecting the information to statistical or other analysis and collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our subsidiaries within India or internationally.
We use Personal Information only for the following purposes: (i) to administer the Services, (ii) to provide, improve and optimize the Services, (iii) to personalize your experience, (iv) to provide you with software updates and/or product announcements, (v) to better understand users’ needs and interests, and (vi) to provide you with further information and offers from us that we believe you may find useful or interesting, such as targeted advertising and promotional campaigns.
We may match data from your transactions with Merchants and/or the content information with our usage data in a personally identifiable form in order to perform accounting reconciliation and/or provide targeted offers and/or rewards or discounts to you; but to protect your privacy, our Merchants and Vito will perform this matching in a protected environment that does not allow our Merchants to gain Personal Information you have not opted in to disclose to them, unless you choose to identify yourself at the Merchant’s store as a Vito user to use an offer or redeem a reward (e.g., by telling the store’s cashier your cell phone number, or by using a loyalty account that has been linked to your Vito account). By enabling a Merchant to identify you as a Vito user, you are allowing them to identify and store that transaction as a Vito-related transaction along with your Vito identifier.
Non-Personally Identifiable Information
We may use Non-Personally Identifiable Information for a few purposes. We may analyze trends through aggregated demographic and psychographic information about our users generally, and thus, for example, to improve features and functionality of the Services and to make more relevant offers to users. We may also share this Non-Personally Identifiable Information with our Merchants to allow them to assist us in delivering tailored advertisements, promotions, sweepstakes, discounts, and other incentives to you when you use the Services. Any information shared with Merchants in this context will not contain nor be linked to your Personal Information unless you have given us your explicit consent through an “opt-in” mechanism on the Application. For example, a Merchant may want to offer a discount on its products to a certain audience (for example, men ages 18-34) or audience segment (for example, women ages 25-40 who have viewed certain content). If the Non-Personally Identifiable Information that we have collected about you meets this description, you would be able to view and use the discount offered by the Merchant.
Loyalty Card Information and Merchants
If you have entered a store loyalty card number of a participating store or other Merchant who the Services are being sponsored by, or whose brand, product or service name(s) are included on the Services, or for whom the Services are provided in partnership with (“Merchant”), we may share Personal Information with that Merchant, including your loyalty card number (but as to data regarding your usage of Services, only the usage data that relates to that Merchant will be shared). In addition, we may request your permission to allow us to share your Personal Information with Merchants; you are not required to grant such permission in order to use the Services, but if you do consent, we may share Personal Information with one or more Merchants (as to data regarding your usage of Services, though, only the usage data that relates to a particular Merchant will be shared with that Merchant). In all other cases, we will only share data with Merchants in an aggregated (i.e., not personally identifiable) form for analysis and marketing purposes, with the goal to improve the Services further, or to permit the Merchant to analyze the effectiveness of its marketing efforts. If we share Personal Information with a Merchant, we will require in our agreement with that Merchant that this information not be shared outside the Merchant except to contractors or service providers for use solely to supply operational or analysis services to that Merchant, but we cannot ensure our Merchants’ compliance with these agreements.
We may use “cookies” (a cookie is a small data file that is kept in your device’s memory for record-keeping purposes), and/or other storage on your device to help us collect, maintain, and use this information, for two purposes. First, to make the interactions easier and more personalized for you, we may utilize persistent cookies to save information relating to your Account and/or activity for future interactions with the Services. Second, to better understand how you interact with the Services and to monitor aggregate usage by Vito users and web traffic routing on the Services, we utilize session ID cookies to enable certain features of the Services. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Services and then close your browser. Third party advertisers on the Services may also place or read cookies on your browser. At any time, you can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Please understand that if you do not accept cookies, you may not be able to use all portions or all functionality of the Services.
When Do We Share Information?
We will not share your Personal Information with anyone else except to provide the Services, when we otherwise have your permission, or under the following circumstances:
Non-Personally Identifiable Information. As discussed above, we may share with third parties or the public (e.g., through white papers or press articles) aggregated information in a form that does not disclose your Personal Information, nor be reasonably likely to allow you to be personally identified, for industry analysis, demographic profiling and similar purposes. We share this aggregated information so that our partners also understand how interested our users are in their products and services, so that they may also provide you with an optimal online experience, and so that additional retail or brand partners can see the opportunity in Vito and may also become partners and further enrich the Services and offers for our users.
Service Providers or Agents. We may employ or partner with third party companies and individuals to process your payments, facilitate our Services, to provide all or a portion of Services on our behalf, to perform Services-related services (e.g., without limitation, maintenance services, database management, web analytics, download provisioning and improvement of the Services’ features) or to assist us in analyzing how our Services are used. These third parties may have access to your Personal Information but only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. In some instances, these third parties will be able to make use of Non-Personally Identifiable Information for other purposes.
Compliance with Laws and Law Enforcement. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We reserve the right to track IP addresses for the purposes of fraud prevention, and to release IP addresses to legal authorities. We will disclose information about you to government or law enforcement officials or private parties when we believe reasonably necessary to comply with law, to protect the property and rights of Vito or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
Business Transfers. We may sell, transfer or otherwise share your Personal Information in connection with a merger, acquisition, reorganization or sale of our company (or our assets) or in the event of our bankruptcy; this is the only case in which we may sell Personal Information we collect from you or from your use of the Services.
How Can I Change or Delete My Personal Information?
You may review, update, correct or delete your Personal Information in your registration profile by contacting us or by making the appropriate modifications in your Account preferences. If you completely delete all such information, then your account may become deactivated. If you would like us to delete your Account and/or remove your records from our system, please contact us and we will delete your account within 45 days if we do not have any legal obligation to retain the record.
Is My Information Secure?
We employ administrative and electronic measures designed to safeguard and protect your information from unauthorized access and disclosure. In addition, we will delete information after it is no longer useful for providing the Services.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Services in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
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