Privacy Policy

Effective as of August 23, 2020.      

This “Privacy Policy” describes the privacy practices of Vocal Pockets, LLC (Vocal Pockets”, “we”, “us”, or “our”) in connection with the Platform (as defined in our Terms of Use), and the rights and choices available to individuals with respect to their information. Capitalized terms used herein, but not defined have the meaning ascribed to them in the Terms of Use.

Table of Contents

  • Personal Information We Collect
  • How We Use Your Personal Information
  • How We Share your Personal Information
  • Your Choices
  • Other sites, mobile applications and services
  • Security Practices
  • International Data Transfers
  • Children
  • Changes to this Privacy Policy
  • How to Contact Us
  • Notice to European Users
  • Cookie Policy

PERSONAL INFORMATION WE COLLECT

Personal information you provide to us.  Personal information you may provide to us through the Platform or otherwise includes:

  • Contact data, personal or business contact information such as your first and last name, email and mailing addresses, phone number, professional title and company name.
  • Registration data, such as information that you provide to register for an account or sign up for an event, including the day and month of your birth.
  • Data about others for whom you may refer to the Platform.
  • Profile data, such as your username and password that you may set to establish an online account with us and your interests and preferences.
  • Communications, such as information you provide when you contact us with questions, feedback, survey responses, or otherwise correspond with us.
  • Marketing data, such as the email address or contact details that we use to send marketing communications and your preferences for receiving communications about any events, sweepstakes and contests.
  • Purchase data, including your order history and information needed to process and fulfill your order, including order details.
  • Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Data from other sources.  We may also collect information about you from:

  • Business partners, such as advertising and joint marketing partners.
  • Data providers, such as information services and data licensors.
  • Public sources, such as blogs, forums or social media platforms.

Automatic collection.  We and our service providers may automatically log information about you, your computer or mobile device, and your activity occurring on or through the Services (as defined in our Terms of Use), such as:

  • Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, the website you visited before browsing our site, and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths on or between pages or screens, information about your activity on a page or screen, access times, and duration of access.

Cookies and similar technologies.  Some of our automatic data collection is facilitated by cookies and similar technologies.  See our Cookie Policy for more information. 

Referrals.  Users of the Service may have the opportunity to refer friends or other contacts to us.  If you are an existing user, you may only submit a referral if you have permission to provide their contact information to us so that we may contact them.

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

Service delivery.  We may use your personal information to:

  • provide, operate and improve the Platform, such as to enable you to make purchases of Products (as defined in our Terms of Use) that we have made available through the Services;
  • establish and maintain your account on the Services;
  • communicate with you about the Platform, including by sending you announcements, updates, security alerts, and support and administrative messages;
  • provide customer support and maintenance for the Platform;
  • facilitate your log in to the Services; and
  • enable security features of the Services, such as by sending you security codes via email, and remembering devices from which you have previously logged in.

Direct Marketing.  We may use your personal information to send you Vocal Pockets-related marketing communications as permitted by law.  You will have the ability to opt-out of our marketing and promotional communications as described in the “Your Choices” section below.

Promotional Marketing.  When you make a purchase or provide us with feedback through the Services (including via email), we may use your first name, city and state to promote the Platform in connection with such feedback or purchase.

For research and development.  We may use your personal information for research and development purposes, including to analyze and improve the Platform and our business. 

To create anonymous data.  We may create aggregated, de-identified or other anonymous data records from your personal information and other individuals whose personal information we collect.  We make personal information into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Platform and promote our business.

Interest-based advertising.  We may contract with third-party advertising companies and social media companies to display ads through our Services and other sites.  These companies may use cookies and similar technologies to collect information about you (including the device data, online activity data and/or geolocation data described above) over time across our Services and other sites and services or your interaction with our emails, and use that information to serve ads that they think will interest you.  These ads are known as "interest-based advertisements." You can learn more about your choices for limiting interest-based advertising, in the Your Choices section below and our Cookie Policy.

To comply with laws and regulations.  We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities. 

For compliance, fraud prevention and safety.  We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) audit our internal processes for compliance with legal and contractual requirements; (c) enforce the terms and conditions that govern the Platform; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyber attacks and identity theft.

With your consent.  In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law. 

HOW WE SHARE YOUR PERSONAL INFORMATION

We may share your personal information with the following third parties and as otherwise described in this Privacy Policy or at the time of collection:

Affiliates.  Any of our subsidiaries and affiliates, for purposes consistent with this Privacy Policy. 

Service providers.  Companies and individuals that provide services on our behalf or help us operate the Platform or our business (such as order fulfillment, payment processing, customer support, hosting, analytics, email delivery, marketing, database management services, returns processing and risk and fraud mitigation). Please note, we do not control the third party’s use of your personal information.

Advertising partners.  Third party advertising companies that collect information about your activity on the Site and other online services to help us advertise our services, and/or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms. 

The public.  Other users of the Services and the public, when you disclose personal information for public use.  For instance, you may be able review a product that you purchased, and we may display your first name, city and state along with the content you submit.  We do not control how other users or third parties use any personal information. Please be aware that any information you post publicly can be cached, copied, screen captured or stored elsewhere by others (e.g., search engines) before you have a chance to edit or remove it.

Professional advisors.  Professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others.  Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate to comply with law or for the compliance, fraud prevention and safety purposes described above.

Business transferees.  We may sell, transfer, or otherwise share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets, or in the event of an insolvency, bankruptcy, or receivership.

YOUR CHOICES

In this section, we describe the rights and choices available to all users.

Access or update your account information.  If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

Opt out of marketing communications.  You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions located at the bottom of the email.  At any time, including after making a purchase, you can also opt out of marketing emails by contacting us here. You may continue to receive service-related and other non-marketing emails. If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message. 

Cookies.  Most browsers let you remove and/or stop accepting cookies from the websites you visit.  To do this, follow the instructions in your browser’s settings. For more details, see the “Your Choices” section of our Cookie Policy. 

Advertising Choices.  You may opt-out of interest-based advertising. See the “Your Choices” section of our Cookie Policy for more information. 

Do Not Track.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Choosing not to share your personal information.  If you do not provide information that we need to provide the Platform, we may not be able to provide you with the Platform or certain features.  We will tell you what information you must provide to receive the Platform when we request it.

OTHER SITES, APPLICATIONS AND SERVICES

The Services may contain links to other websites and online services operated by third parties, such as links to the Resource Center which may be provided by a third party, such as FreshDesk/FreshWorks.  These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us.  We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information.  We encourage you to read the privacy policies of the other websites and online services you use. 

SECURITY PRACTICES

The security of your personal information is important to us.  We employ a number of safeguards designed to protect the personal information we collect.  However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

INTERNATIONAL DATA TRANSFERS

Vocal Pockets is headquartered in the United States and may have service providers in other countries.  Your personal information may be transferred to the United States or other locations outside of your state, province, country, or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction. 

CHILDREN

The Service is not intended for use by children under 16 years of age, and we do not knowingly collect information about children under age 16 through the Services.  If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian as required by law, we will delete it.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Site. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail or another manner through the Services.

Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

HOW TO CONTACT US 

Please direct any questions or comments about this Policy or privacy practices to us here.  You may also write to us via postal mail at:

Vocal Pockets, LLC

90 State St. Suite 700 Office 40

Albany, NY, 12207

NOTICE TO EUROPEAN USERS

The information provided in this “Notice to European Users” section applies only to individuals in the European Union, the European Economic Area or the United Kingdom (collectively, “Europe”).

Personal information.  Except as otherwise specified, references to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.  

Controller. The controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation is Vocal Pockets, LLC, 90 State St. Suite 700 Office 40, Albany, NY, 12207. 

Legal bases for processing.  The legal bases of our processing of your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it.  However, the legal bases we typically rely on are set out in the table below. We rely on our legitimate interests as our legal basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, contact us here

Processing purpose

Legal basis

Service delivery

Processing is necessary to perform the contract governing our operation of the Services or the provision of the Services, or to take steps that you request prior to engaging our services.  Where we cannot process your personal data as required to operate the Services on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interest in providing you with the products or services you access and request. 

Marketing

Interest-based advertising

Processing is based on your consent where that consent is required by applicable law.

Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our business, and showing you tailored relevant content.

For research and development

To create anonymous data

For compliance, fraud prevention and safety

 

These activities constitute our legitimate interests.

To comply with laws and regulations

Processing is necessary to comply with our legal obligations.

With your consent

Processing is based on your consent.  Where we rely on your consent, you have the right to withdraw it any time in the manner indicated when you consent or via the Services. 

 

Use for new purposes.  We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it.  If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis. 

Sensitive personal information.  Unless we specifically request it, we ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services, or otherwise to us.

Retention.  We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.  When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information until deletion is possible. 

Your rights.  European data protection laws give you certain rights regarding your personal information.  You may ask us to take the following actions in relation to your personal information that we hold:

  • Access.  Provide you with information about our processing of your personal information and give you access to your personal information.
  • Correct.  Update or correct inaccuracies in your personal information.
  • Delete.  Delete your personal information.
  • Transfer.  Transfer a machine-readable copy of your personal information to you or a third party of your choice.
  • Restrict.  Restrict the processing of your personal information.
  • Object.  Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights. 

You may submit these requests to us here or our postal address provided above.  We may request specific information from you to help us confirm your identity and process your request.  Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.  If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us here or submit a complaint to the data protection regulator in your jurisdiction.  You can find your data protection regulator here

COOKIE POLICY

You can access our Cookie Policy here.