Vatkin understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits Our Site and the Websites and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.
- what personal information we collect (defined as Personal Information below);
- how we use and/or share your Personal Information;
- how we ensure your privacy is maintained; and
- your legal rights relating to your Personal Information.
1. Collection of Information.
Survey Information. Vatkin collects information from individuals by various methods, including, but not limited to, when a Vatkin survey, order form, or a registration page either online or offline, or by means of online or offline surveys, order forms, or registration pages operated by third parties (collectively, a “Survey”). (As used herein, “online” means using the Internet, including the Websites, and related technologies, and “offline” means by methods other than online, including in person, in the postal mail, using telephones and cell phones, and other similar means.) In the Surveys, Vatkin or a third party (a “Third Party”) may ask an individual to provide various information to Vatkin, which may include his or her name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, social security number, employment information, personal and online interests, and such other information as may be requested from time to time (together, “Survey Information”). Vatkin may also collect information concerning an individual from another source and use that information in combination with information provided from this web site. Completing the Survey is completely voluntary, and individuals are under no obligation to provide Survey Information to Vatkin, or any Third Party, but an individual may receive incentives from Vatkin, or a Third Party in exchange for providing Survey Information to Vatkin.
Third Party List Information. Vatkin, collects information from individuals when an individual provides information to a third party and Vatkin. Subsequently, purchases, licenses, or otherwise acquires the information from the third party (the “Seller”). Such purchased information may include, but is not limited to, an individual’s name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, credit card information, education and marital status, occupation, industry of employment, personal and online interests, and such other information as the individual may have provided to the Seller (together, “Third Party List Information”). When acquiring Third Party List Information, Vatkin seeks assurances from the Seller that the Seller has a right to transfer the Third-Party List Information to Vatkin, and that the Seller has a right to provide offers from advertisers to the individuals whose personal information is included on the Seller’s list.
Other Information. Other occasions when Vatkin obtains information from individuals include (1) when an individual is making a claim for a prize or seeking to redeem an incentive offered by Vatkin. by a third party, (2) when an individual requests assistance through Vatkin customer service department, and (3) when an individual voluntarily subscribes to a Vatkin service or newsletter (together, “Other Information”).
Cookies and Other Info Collected Using Technology. Vatkin currently uses cookie and web beacon technology to associate certain Internet-related information about an individual with information about the individual in our database. Additionally, Vatkin may use other new and evolving sources of information in the future (together, “Technology Information”).
(a) Cookies. A cookie is a small amount of data stored on the hard drive of the individual’s computer that allows Vatkin to identify the individual with his or her corresponding data that resides in Vatkin database. You may read more about cookies at http://cookiecentral.com. Individuals who use the Websites need to accept cookies to use all of the features and functionality of the Websites.
(b) New Technology. The use of technology on the Internet, including cookies and web beacons, is rapidly evolving, as is Vatkin’s use of new and evolving technology. As a result, Vatkin strongly encourages individuals to revisit this policy for any updates regarding its use of technology.
Outside Information. Vatkin may receive information about individuals from third parties or from other sources of information outside of Vatkin. Including information located in public databases (“Outside Information”).
Personal Information. As used herein, “Personal Information” means Survey Information, Third Party List Information, Other Information, Technology Information, and Outside Information, and any other information Vatkin gathers or receives about individuals.
No Information Collected from Children. Vatkin will never knowingly collect any personal information about children under the age of 13. If Vatkin obtains actual knowledge that it has collected personal information about a child under the age of 13, that information will be immediately deleted from our database. Because it does not collect such information, Vatkin has no such information to use or to disclose to third parties. Vatkin has designed this policy in order to comply with the Children’s Online Privacy Protection Act (“COPPA”).
Credit Card Information. Vatkin may in certain cases collect credit card numbers and related information, such as the expiration date of the card (“Credit Card Information”) when some individual places an order from Vatkin. When the Credit Card Information is submitted to Vatkin, such information is encrypted and is protected with SSL encryption software. Vatkin will use the Credit Card Information for purposes of processing and completing the purchase transaction, and the Credit Card Information will be disclosed to third parties only as necessary to complete the purchase transaction.
2. Use of Personal Information.
Discretion to Use Information. THE COMPANY MAY USE PERSONAL INFORMATION FOR ANY LEGALLY PERMISSIBLE PURPOSE AT COMPANY’S SOLE DISCRETION AND/OR WHERE YOU HAVE GIVEN EXPRESS CONSENT. We set out in Section 7 the legal bases under the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”) relied upon by Vatkin to justify its proper use of Personal Information. The following paragraphs in Section 2 describe how Vatkin currently uses Personal Information, but Vatkin may change or broaden its use at any time. As noted below, Vatkin may update this policy from time to time.
Vatkin may use Personal Information to provide promotional offers to individuals by means of email advertising, telephone marketing, direct mail marketing, online banner advertising, and package stuffers, among other possible uses.
You have the right to opt out of receiving promotional communications at any time, by:
- changing your preferences by contacting us
- making use of the simple unsubscribe link in emails; and/or
Email. Vatkin uses Personal Information to provide promotional offers by email to individuals. Vatkin may maintain separate email lists for different purposes. If email recipients wish to end their email subscription from a list, they need to follow the instructions at the end of each email message to unsubscribe from the particular list.
(a) Content of Email Messages. In certain commercial email messages sent by Vatkin, an advertiser’s name will appear in the “From:” line but hitting the “Reply” button will cause a reply email to be sent to Vatkin. The “Subject:” line of Vatkin email messages will usually contain a line provided from the advertiser to Vatkin.
(b) Solicited Email. Vatkin only sends email to individuals who have agreed on the Websites to receive email from Vatkin or to individuals who have agreed on third party websites to receive email from third parties such as Vatkin. Vatkin does not send unsolicited email messages. As a result, statutes requiring certain formatting for unsolicited email are not applicable to Vatkin’s email messages.
Targeted Advertising. Vatkin uses Personal Information to target advertising to an individual. When an individual is using the Internet, Vatkin uses Technology Information (see also the section on Technology Information below) to associate an individual with that person’s Personal Information, and Vatkin attempts to show advertising for products and services in which the person has expressed an interest in the Surveys, indicated an interest by means of Technology Information, and otherwise. Vatkin may, at its discretion, target advertising by using email, direct mail, telephones, cell phones, and other means of communication to provide promotional offers.
Direct Mail and Telemarketing. Vatkin uses Personal Information to advertise, directly or indirectly, to individuals using direct mail marketing or telemarketing using telephones and cell phones.
HOW DO WE USE YOUR PERSONAL DATA
We may contact you with our latest offers and/or promotions that we think might interest you, as part of our market research, either by mail, telephone or e-mail.
Our communications are designed to tell you about the benefits
we can offer, so that you will be notified of our latest deals, offers and promotions. We use the information we collect about you to tailor the content you receive and try to ensure that the offers are as relevant to you as possible.
In addition, the personal information you provide may be used for the purposes of identity verification, credit and risk management, revenue collection, database verification and enhancement.
We may also share your details with carefully selected and trusted partners whose product or services we think might interest you, either directly or through a data co-operative. We only share your details with our trusted partners whom will only contact you via postal communications and we never share email or telephone contact information for marketing communication purposes. You have the right to object to your information being shared with our partners and if you wish to do so please contact us at firstname.lastname@example.org
Data Co-operatives are companies whose members contribute information about their consumers in exchange for information about other consumers that may be interested in their products. They are just as protective as we are regarding the security and privacy of your data and adhere to the latest standard and regulations to prevent the loss or unauthorised use.
Use of Technology Information. Vatkin uses Technology Information (1) to match a person’s Survey Information and Third Party List Information to other categories of Personal Information to make and improve profiles of individuals, (2) to track a person’s online browsing habits on the Internet, (3) to determine which areas of Vatkin’s websites are most frequently visited. This information helps Vatkin to better understand the online habits of individuals so that Vatkin can target advertising and promotions to them.
Profiles of Individuals. Vatkin uses Personal Information to make a profile of an individual. A profile can be created by combining Survey Information and Third Party List Information with other sources of Personal Information such as information obtained from public databases.
3. Dissemination of Personal Information.
Order Fulfillment. Vatkin will transfer Personal Information to third parties when necessary to provide a product or service that a person orders from such a third party while using Vatkin websites or when responding to offers provided by Vatkin.
Legal Process. Vatkin may disclose Personal Information to respond to subpoenas, court orders, and other legal processes.
Access. Individuals have access to their Personal Information collected to provide an opportunity for an individual to correct, amend, or delete such information. Access can be obtained by contacting customer service at the number on the order page. Vatkin may also grant advertising clients and email services providers access to an individual’s email address to verify the origin of the Personal Information collected.
4. How We Protect Your Privacy.
Storage of Personal Information. Vatkin stores the Personal Information in a database on Vatkin computers. Vatkin is committed to keeping your Personal Information safe and secure.
Our security measures include:
- our IT systems have security measures (such as a firewall) in place to protect against the loss, misuse, and alteration of the information under Vatkin’s control;
- robust encryption of data;
- regular scenario planning and crisis management exercises to ensure we are ready to respond to cyber security attacks and data security incidents; and
- internal policies setting out our data security approach and training for employees.
Notwithstanding such measures, Vatkin cannot guarantee that its security measures will prevent Vatkin computers from being illegally accessed, and the Personal Information on them stolen or altered.
5. Privacy Practices of Third Parties.
Advertising agencies, advertising networks, and other companies (together, “Advertisers”) who place advertisements on the Websites and on the Internet generally may use their own cookies, web beacons, and other technology to collect information about individuals. Vatkin does not control Advertisers’ use of such technology and Vatkin has no responsibility for the use of such technology to gather information about individuals.
Links. The Websites and email messages sometimes contain hypertext links to the web sites of third parties. Vatkin is not responsible for the privacy practices or the content of such other websites. Linked web sites may contain links to web sites maintained by third parties. Such links are provided for your convenience and reference only. Vatkin does not operate or control in any respect any information, software, products or services available on such third party websites. The inclusion of a link to a web site does not imply any endorsement of the services or the site, its contents, or its sponsoring organization.
6. Your Rights
You have the following rights:
- the right to ask what Personal Information that we hold about you at any time,
- the right to ask us to update and correct any out-of-date or incorrect Personal Information that we hold about you free of charge; and
- (as set out above) the right to opt out of any marketing communications that we may send you.
If you wish to exercise any of the above rights, please contact us using the contact details set out below.
You may also file a complaint with the competent authority responsible for data protection or lodge an appeal if your Personal Information is misused.
7. Legal basis for Vatkin processing customers’ Personal Information
Vatkin collects and uses customers’ Personal Information because it is necessary for:
the pursuit of our legitimate interests (as set out below);
the purposes of complying with our duties and exercising our rights under a contract for the sale of goods to a customer; or
complying with our legal obligations.
Our legitimate interests
We may process your personal information for our legitimate business interests. ‘Legitimate Interests’ means the interests of our company in conducting and managing our business to enable us to give you the best service/products and the best and most secure experience. It can and does also apply to processing which is in your interests too.
The normal legal basis for processing Personal Information, is that it is necessary for the legitimate interests of Vatkin including:
- selling and supplying goods and services to our customers;
- protecting customers, employees and other individuals and maintaining their safety, health and welfare;
- promoting, marketing and advertising our products and services;
- certain direct marketing and promotional activities;
- the provision and operation of referral marketing programmes;
- network and information systems security;
- data analytics;
- enhancing, modifying or improving our service;
- identifying usage trends;
- determining the effectiveness of promotional campaigns or advertising;
- sending promotional communications which are relevant and tailored to individual customers;
- understanding our customers’ behaviour, activities, preferences, and needs;
- improving existing products and developing new products;
- complying with our legal and regulatory obligations;
- preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
- handling customer contacts, queries, complaints or disputes;
- managing insurance claims by customers;
- protecting Vatkin, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to Vatkin;
- effectively handling any legal claims or regulatory enforcement actions taken against Vatkin; and
- fulfilling our duties to our customers, colleagues, shareholders and other stakeholders.
In connection with the above activities, we may share your personal information with trusted suppliers who assist us in our data processing activities. For a list of our current suppliers with whom we share data and what they do with that data, please click here.
When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).
You have the right to object to this processing if you wish and if you wish to do so please contact email@example.com
9. Contact Vatkin
You can contact us to update your Personal Information or change your preferences. Our contact information for these purposes is as follows:
By email at firstname.lastname@example.org
Please note that it may take up to 30 days for you to stop receiving emails once you have requested to opt-out of any marketing communications.