This Privacy Policy for Vermillio, Inc. (“Vermillio”, “we”, “us” “our”) describes how we collect, use and disclose information about users and visitors of our platform, available at www.vermill.io (the “Platform”), services, tools, features and functionalities, and applications where we offer additional services, tools, and features (“Applications”) (collectively, the “Services”). For purposes of this Privacy Policy, “you” and “your” means you as the user of the Services. Any defined terms used in this Privacy Policy, but not defined within this policy, have the meanings ascribed in our Terms of Service or End User Terms of Service, as applicable. 

For the purpose of applicable data protection laws, we are the data controller. 

If we make changes to this Privacy Policy, we will update the last revised date, post the updated version on our Platform and take any other steps necessary to comply with applicable law.    

PLEASE READ THIS PRIVACY POLICY CAREFULLY. Certain Applications that Vermillio offers may be subject to supplemental privacy policies which will be provided to you in the Application. Please read these additional policies to understand how your personal information is further used by these Applications. If you do not want information about you used as described in this Privacy Policy, please do not access or use the Services. 

1. HOW WE COLLECT AND USE INFORMATION ABOUT YOU

When you access or use our Services, or otherwise engage with us, we may ask you to provide us with the following information about you:

• Contact information: Name, email address, and social media handles. We collect this information to create and maintain your Account, communicate with you about our Services (including to tell you about additional Services that may be of interest to you), respond to your queries, and administer surveys.
• Account information: Username, display name, password, security questions. We collect this information to create, maintain and secure your Account. If you choose to register an Account, you are responsible for keeping your Account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your Account has been compromised, please contact us immediately via security@vermill.io.
• Payment information: Credit/debit card information and billing address. We collect this information to complete transactions and provide you with product(s) that you have requested, for example, when you purchase Third Party IP. 
• Information about your use of the Services: Third Party IP that you buy or show interest in, your activity on the Content Marketplace and other uses of the Services. We collect this information to facilitate your engagement with the Services, personalize your experience, monitor and analyze trends in connection with the Services and conduct internal research and development.
• Any other information you choose to provide: This includes reviews of our Services or Third Party IP, pictures and videos, gender, responses to surveys/quizzes and any other information that you choose to include in communications with us, for example, when sending us an email. We use this information to facilitate your engagement with the Services, including to enable you to post comments and reviews, to engage with other users, to post on social media, communicate with you about our Services, administer surveys, personalize your experience, monitor and analyze trends in connection with the Services and conduct internal research and development.

Some features of the Services may require you to enter certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.

Any information that we receive from outside sources will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for their policies or practices. See Section 5 below for more information. 

In addition, our Platform, like most websites, uses third party tools, including cookies, pixels and other tracking technologies (“Tracking Technologies”), including Google Analytics, to provide and enhance the performance of our Services, facilitate and enhance user experience, monitor and analyze trends, usage and activities in connection with the Services and conduct internal research and development. For further information about Google Analytics, please click here. The information we collect through Tracking Technologies include:

• Details of the devices used to access our Platform, such as unique device identifier, browser type, device type, and operating system information.
• IP address.
• Date and time stamps, such as the date and time you first accessed the Services.
• Log data.
• Other information regarding your interaction with the Services, such as clickstream data and which emails you may have opened.

We use Tracking Technologies that perform the following purposes:

• Essential Tracking Technologies, which are essential to the functioning of our Services, to provide a service requested by you or to comply with the law (e.g. the security requirements of data protection law). We do not need to obtain your consent in order to use these Tracking Technologies and these Tracking Technologies cannot be turned off as we cannot provide the Services without them.
• Functionality Tracking Technologies, which allow us to remember choices you make and provide enhanced and personalized features e.g. to show you when you are logged in.
• Performance Tracking Technologies, which enable us to collect information about your online activity (e.g. the duration of your use of the Services), including behavioral data and content engagement. They allow us to provide you with a better user experience and to maintain, operate and continually improve the Services.

We may associate this information with your Account (if you have a registered account), or the Account of another user (e.g., if you purchased Third Party IP from another user, or vice versa), the device you use to access the Services, or email or social media accounts that you use to engage with Vermillio. 

In addition to the specific uses of information described above, we may use all of the above information to provide, improve and develop the Services and our product offerings, including as we describe in our Platform Terms of Service and End User Terms of Service, to comply with any applicable legal obligations, to enforce any applicable terms of service, to protect or defend the Services, our rights, the rights of our users, or others, for the purpose of combating fraud, or to otherwise operate our business.

2. PURPOSE AND LEGAL BASIS FOR PROCESSING

Some jurisdictions require that we determine a “lawful basis” for processing personal information. Where such requirements exist, we rely on the following lawful bases for our processing activities: that you have consented to the processing; that the processing is necessary for the performance of our contract with you; that we have a legal obligation; or that we have a legitimate interest in providing and improving the Services and managing our business operations.

3. HOW WE SHARE INFORMATION ABOUT YOU

We may share information about you, including the above categories of information, with third parties in the following circumstances: 

• With service providers, including cloud storage providers, security vendors, data analytics vendors, and payment processors.
• When you request that we share certain information with third parties, such as through your use of social media widgets, login integrations, or interactions with other users on the Platform.
• With our other Applications, affiliates or otherwise within our corporate group.
• To comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
• In connection with an asset sale, merger, bankruptcy, or other business transaction.
• To enforce any applicable terms of service.
• To ensure the safety and security of Vermillio and our users.
• With professional advisors, such as auditors, law firms, or accounting firms.

4. COOKIES AND OTHER TRACKING TECHNOLOGIES

Do Not Track Signals

Your browser settings may allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our Platform is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.

Cookies and Other Tracking Technologies

Most browsers accept cookies automatically. However, you may be able to configure your browser settings to use the Services without some cookie functionality and/or control the way in which your devices permit the use of Tracking Technologies. For example, you can delete cookies manually or set your browser to automatically delete cookies on a predetermined schedule.  

If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including any portal features and general functionality, to work incorrectly. 

5. THIRD PARTY WEBSITES AND LINKS

6. CHILDREN’S PRIVACY

Children under the age of 13 are not permitted to use the Services, and we do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database.

If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

7. CALIFORNIA RESIDENTS

Any California residents under the age of eighteen (18) who have registered to use the Services, and who have posted content or information on the Services, can request that such information be removed from the Services by contacting us at the e-mail address set forth in the “Contact us” section below. Such a request must state that they personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished the post and archived copies of it may be stored by search engines and others that we do not control.

Terms used in this section and not otherwise defined have the meaning given to them under the California Consumer Privacy Act, as amended by the California Privacy Rights Act. 

We do not sell personal information collected about you or share it for targeted advertising purposes. We do not have actual knowledge that we sell personal information of individuals under 16 years of age.

In the preceding 12 months, we collected and disclosed for a business purpose the following categories of personal information about California consumers:

Category	Examples	Categories of Recipients
Identifiers	Name, e-mail address, IP address	Vendors, including, Cloud storage providers, security vendors, data analytics vendors, and payment processors; affiliates
Commercial information	Records of products or services purchased	Vendors, including, Cloud storage providers, security vendors, data analytics vendors, and payment processors; affiliates
Internet or other similar network activity	Information regarding your interaction with the Platform	Data analytics vendors; affiliates
Geolocation data	IP address	Vendors, including, Cloud storage providers, security vendors, data analytics vendors, and payment processors; affiliates
Professional or employment-related information	Title of profession, employer, professional background	Vendors, including, cloud storage providers, security vendors, data analytics vendors, and payment processors; affiliates
Inferences drawn from other personal information	Profile reflecting your preferences	Data analytics vendors; affiliates

8. YOUR RIGHTS

Depending on your location, you may have some or all of the following rights in relation to personal information we have collected, subject to verification and any applicable exceptions:

• Know/Access: The right to request that we disclose certain information to you, including the personal information we hold about you, and information about our collection and use of certain personal information about you.
• Correction: The right to correct inaccurate personal information about you.
• Deletion: The right to request that we delete personal information about you.
• Restriction/Opt Out: The right to restrict processing or opt out of certain types of processing, such as the sale of personal information about you to third parties, or the use of your personal information for targeted advertising or profiling in furtherance of decisions that produce legal or similarly significant effects regarding yourself. 
• Limitation: The right to limit the use and disclosure of sensitive personal information about you to certain specific usages.
• Portability: The right to obtain the personal data in a portable format when exercising the right to access personal information about you.
• Withdraw Consent: The right to withdraw consent where processing is based on consent.
• Freedom from Discrimination: The right to be free from unlawful discrimination for exercising any of the rights above.
• Appeal: The right to appeal a decision we have made in response to your request to exercise your rights.

To make a request in relation to the above rights, please contact us using the information in the “Contact Us” section below.  To fulfill your request, we may need to verify your identity and country or state of residency, and may ask for additional information and documents. Only you, or someone legally authorized to act on your behalf, may make a request related to personal information collected about you. To designate an authorized agent, the authorized agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on their behalf.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the data protection authority of your country or state of residence.

9. DATA RETENTION AND STORAGE

We will retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes and enforce our terms and conditions, other applicable terms of service, and our policies. If you stop using our Services, we may store your information in an aggregated and anonymized format; we may use this information indefinitely without further notice to you.

10. DATA SECURITY

Please be aware that, despite our reasonable efforts to protect your information, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Please further note that any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. Any information you transmit to us you do at your own risk. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us.

11. DATA TRANSFERS

As we are a United States company, if you are accessing the Services or providing information from outside the United States, the personal information you provide to us may be transferred to, stored in, and/or processed within the United States or other countries where we or our service providers maintain facilities or business operations. Such countries may have data protection rules that are different and less protective than those of your country.

We may transfer your information based on your consent, or, in some cases, in reliance on appropriate safeguards in accordance with legal requirements, such as applicable standard contractual clauses. 

You may contact us using the contact information below to learn more about the appropriate safeguards that may apply to your personal information and to request a copy of such safeguards. 

12. HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Policy, please email us at accountservices@vermill.io.