Last Updated: [8/1/23]

This Privacy Policy describes the data practices of Vladimir Jones (“we,” “our,” or “us”) for information collected through the website vladimirjones.com, digital properties, and any other services or products linked to this policy (collectively the “Site”). It includes information about data we collect, how it is used, and who it is shared with. For client services, Vladimir Jones acts as a service provider/processor within the meaning of U.S. state privacy laws.. The policy may be updated from time to time to reflect changes in Vladimir Jones business practices or legal requirements. 

This Privacy Policy does not apply to personal information collected by any third-party websites or services that may be linked to or from our website or services. We encourage our customers to review the privacy policies of any third-party websites or services they use.

INFORMATION COLLECTION

We collect information from the Site in order to provide our services and fulfill our contractual obligations. This may include:

• Information You Voluntarily Provide to Us – We collect information including [your name, mailing and/or billing address, telephone number, and email address/insert other data elements collected]. We collect this information when you [communicate with us, create an account, make a purchase, request information, or when you otherwise provide it to us/insert other applicable data capture activity]. 

• Information Collected by Automated Means – Whenever you use the Site, we, as well as any of our third-party advertisers and/or service providers, may use a variety of technologies that automatically collect information about how the Site is accessed and used. This information may include, in part, browser type, operating system, demographic information, the page served, the time, how many users visited the Site, and the website you visited immediately before the Site. This data provides us with [information about the use of the Site, such as how many visitors visit a specific page on the Site, how long they stay on that page, and which hyperlinks, if any, they “click” on/insert other applicable information]. 

• Device Identifiers – In the course of collecting information on the Site, we may also collect your [IP address, MAC Address or other unique device identifier for the computer, mobile device, or other technology you use to access the Site, and other information we collect through the use of cookies and similar technology]. See the “Digital Advertising and Analytics” section of this privacy policy to learn more about the use of this information and the choices available to you.

We may also collect information from other sources, such as third-party service providers or public records, in order to provide our services and fulfill our contractual obligations. 

INFORMATION USE

We may use your information for any lawful purpose, including the following:

• To communicate with you about our services;
• To provide customer support;
• To conduct market research and analysis;
• To respond to your inquiries;
• To operate and improve our products and services; 
• To operate, personalize, and improve the Site, including for analytics purposes;
• To send updates, promotions, and marketing materials that may be of interest to you;
• To comply with the law and to maintain the security of our Site.

INFORMATION SHARING

We may share the information we collect with third-party service providers who process information on our behalf, such as email marketing providers.

We may also share the information we collect with other parties, including the following:

• Our business partners, suppliers, and sub-contractors;
• Third-party companies, advertisers, advertising networks and social networks so that they may select and serve relevant advertisements to you and others;
• Third-party service providers, such as analytics and search engine providers, email service providers, and web hosting providers;
• To comply with a legal obligation, such as a subpoena or court order, governmental inquiry, or other legal process or as otherwise required by law, to protect our rights or the rights of third parties, or to protect the safety or security of any person or entity;
• To prevent or investigate possible wrongdoing in connection with our services;
• To protect the personal safety of our clients, employees, or the public;
• To protect our legal rights or property;
• As part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets, including as part of a bankruptcy proceeding;
• With any affiliates or joint venture partners that we may have in the future;
• With your consent or as otherwise disclosed at the time of data collection or sharing.

We do not sell personal information to third-party companies for their marketing purposes, unless we have obtained your prior consent. 

We may share information that has been de-identified or aggregated without limitation.

DATA RETENTION

We will retain personal information we collect for as long as necessary to fulfill the purposes for which it was collected, including for the provision of our services, compliance with legal and regulatory requirements, and the protection of our legal rights and interests. We have established retention periods for different categories of information based on the purpose of the processing and legal requirements. 

DIGITAL ADVERTISING AND ANALYTICS

We may partner with ad networks and other ad serving providers (“Advertising Providers”) that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of the Site and other sites or apps over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising.

You may visit the DAA Webchoices tool at www.aboutads.info to learn more about this type of advertising and how to opt out of this advertising on websites by companies participating in the DAA self-regulatory program. If you delete your cookies or use a different browser or mobile device, you may need to renew your opt-out choices exercised through the DAA Webchoices tool. Note that electing to opt out will not stop advertising from appearing in your browser or applications. It may make the ads you see less relevant to your interests.

We may also work with third parties that collect data about your use of the Site and other sites or apps over time for non-advertising purposes. We use Google Analytics and other third-party services to improve the performance of the Site and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our Site, visit www.google.com/policies/privacy/partners, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout.

Additionally, your browser may offer tools to limit the use of cookies or to delete cookies; however, if you use these tools, our Site may not function as intended.

CHILDREN’S PRIVACY

Our services are not directed towards children under the age of 13, and we do not knowingly collect personal information from children under the age of 13. If you are a parent or guardian and believe that we may have collected information about your child, please contact us using the contact information provided at the end of this policy.

STATE PRIVACY RIGHTS

California, Colorado, Connecticut, Utah, and Virginia residents have certain rights under state privacy laws with respect to personal data we collect. If you are a resident of such states, this section of the Privacy Policy contains disclosures required by law and explains rights that may be available to you.

Personal Data We Collect and Disclose. In the preceding 12 months, we collected and disclosed the following categories of personal data: 

• Personal and online identifiers (such as first and last name, email address, or unique online identifiers);

• Characteristics of legally protected classifications (such as race or gender);
• Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement);
• Geolocation information;
• Sensory information (such as call recordings or other audio, electronic, visual, thermal, olfactory, or other similar technology);
• Professional or employment-related information;
• Inferences drawn from the above information about your predicted characteristics and preferences;
• Other information about you that is linked to the personal information above.

We share personal data for targeted advertising purposes but do not otherwise engage in “sales” of personal data as defined by state laws. Additionally, we do not knowingly sell or share personal data of individuals under 16.

Categories of Sources. We collect personal data from the following categories of sources: 

• You;
• Our affiliates and joint venture partners;
• Our business partners; 
• Our service providers; and
• Advertising companies and networks. 

Our Purposes for Processing Personal Data. We use and disclose the personal data we collect for our commercial and business purposes, as further described above in the Information Use section of this Privacy Policy.

We may use and share aggregated and de-identified information to the extent permitted by applicable law.  When we use de-identified information, we maintain and use the information in de-identified form and do not attempt to re-identify it, except to check whether our de-identification processes satisfy the requirements of applicable law.

Recipients of Personal Information. We disclose the categories of personal information designated above to the categories of third parties listed below for commercial and business purposes. 

Your Rights. Residents of certain states have rights with respect to the personal data we collect. You may be able exercise the following rights regarding personal data, subject to certain exceptions and limitations:

• The right to confirm whether we are processing personal data about you.
• The right to know the categories and specific pieces of personal data we collect, use, disclose, and sell about you; the categories of sources from which we collected personal data about you; our purposes for collecting or selling personal data about you; the categories of personal data about you that we have sold or disclosed for a business purpose; and the categories of third parties with which we have shared personal data.
• Depending on your state, the right to receive a portable and readily usable copy of the personal data we have collected about you, to the extent feasible. 
• The right to correct inaccuracies in the personal data we have collected about you. 
• The right to request that we delete the personal data we have collected about you.
• The right to opt out of (i) the sharing of personal data for targeted advertising; (ii) the sale of personal data; or (iii) profiling for decisions that have significant effects.
• Depending on your state, the right to limit our processing of certain “sensitive” personal data (or to withdraw consent for such processing if you previously gave it).
• The right not to receive discriminatory treatment for the exercise of the above privacy rights.

To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:

• Online at vladimirjones.com/contact/
• By emailing us at [email protected]. You can submit any of the above requests by contacting us as described in the Contact Information section.

We do not use or disclose sensitive personal information for purposes other than as permitted under the CCPA.

Additionally, for Colorado, Connecticut, and Virginia residents, if you have submitted a request that we have not reasonably fulfilled, you may contact us to appeal our decision by sending an email with the subject line “Appeal” to the email address;  [email protected]].

Verification Process and Required Information. Note that we may need to request additional information from you to verify your identity or understand the scope of your request. You will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at a minimum, your name, email address, and phone number. 

Authorized Agent. Depending on your state of residence, you may also designate an authorized agent to make requests on your behalf by designating such an agent in writing or through a power of attorney. We will require the agent to provide us with proof that you have authorized the agent to make requests on your behalf prior to accepting requests from the agent.

Your Choices. To opt out of our email marketing, you can use the link provided at the bottom of each marketing message. If you opt out of our email marketing, we will still send you messages related to our transactions and relationship with you.

For choices with respect to third-party interest-based advertising activities, please see the “Digital Advertising and Analytics” section above.

Updating Your Information. When you have an account with us, you may review, change, or update your contact information. Please send an email to [email protected].

CHANGES TO THE PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes to our information practices. We encourage our clients to review this page periodically for the latest information on our privacy practices.

CONTACT INFORMATION

If you have any questions or concerns about this privacy policy, please contact us at:

[email protected]

We will respond to your inquiry as soon as possible and will make every effort to resolve any concerns you may have.