How does this apply to my company?
This statement describes the manner in which VLG either controls or processes data provided by or collected by VLG through a myriad of marketing activities. The majority of our data is provided by and controlled by our customers or their partners. We do not share that controlled data to any third-party without written consent or at the direction of our customers or their partners.
How does this Policy apply to me as a user?
VLG is contracted to provide marketing services on behalf of its customers and their partners. As such, controlled data is shared with us in accordance with our and our customers’ privacy policies. Through the performance of our Services, we also collect and process data. As the controller of this data, we are obligated by contract to share that information with our customer on a “contract-to-hire” basis.
However, should a user wish to exclude their information, we will honor that wish and collected data for that specific user will not be shared with our customers. Similarly, if the user data is controlled by our customer but the user wishes to opt-out, we will record that request and share it with our customers. It would then be up to our customer, the data controller, to carry out the user’s requests.
What is a data controller and a data processor?
For the purposes of this Policy and in accordance with certain domestic and foreign regulations, we act as a “Data Controller” when collecting opt-in data from users. Opt-in data would include information gained with explicit permission from the user, including online behavior tracking and opt-in data submissions (i.e. submitted a form on a website that includes checking an opt-in box).
We take into account the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons. We have implemented appropriate technical and organizational measures to ensure and to be able to demonstrate that processing is performed in accordance with the European General Data Protection Regulation (GDPR). Measures taken will be reviewed and updated where necessary.
For the purposes of this Policy and in accordance with certain domestic and foreign regulations, we act as a “Data Processor” when retained by the Data Controller, either a VLG customer or third-party vendor. We take all steps necessary to protect the rights of the data subject when protecting PII, or processing data.
Please note that the scope of this Policy is limited to information controlled or processed by VLG through your use of the Service. VLG is not responsible for the actions of third-party people or companies, the content of their sites, the use of information you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, or affiliation with, those people or companies.
Where required by law, we obtain consent from individuals to collect, use, retain or disclose their personal data. Individuals located within the European Economic Area are asked to opt-in. If applicable, we inform individuals of the consequences for failing to consent or provide their personal data and the process to alter their consent decisions. VLG verifies that the use of personal data is consistent with the consent obtained. If personal data will be used for a purpose other than that originally disclosed to the individual, we acquire additional consent.
For California residents only. We may disclose your personal information to third parties for their use in processing postage for shipments to you, or on your behalf. Pursuant to California’s “Shine the Light Act,” California residents are permitted to request information about the manner in which we share certain categories of information with third parties. Please send an email to firstname.lastname@example.org to request a copy of our disclosure pursuant to California law. California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/privacy-laws.
We collect information as described below. Our primary goal is to process data and pass those results through to our customers. In all other instances, we collect data to provide services to you, improve our Service, contact you, conduct research, and create reports for internal and external use on behalf of our customers. We store information on Microsoft Azure servers. We collect personal data in a fair, transparent, and lawful manner. As such, we adhere to the following guidelines:
Collect the minimum personal data required to support the Service or as mandated by law;
Collect personal data in a fair and non-deceptive manner;
Where required by local law, obtain explicit consent from individuals, prior to the collection of sensitive personal information (e.g. race, ethnic origin, health details, sexual orientation etc.); andVerify that personal data collected from third parties, including our customers, is reliable and legally obtained.
Furthermore, we monitor the involvement of third parties during collection and conduct due diligence to ensure adherence to our Policy, when possible.
We use personal information collected through our Services for purposes described in this Policy or disclosed to you in our Services or in connection with our Services. For example, we, and by extension our customers, may use your information to:
operate and improve our internal operations, systems, and Services, or those of our customer;
obtain your preferences to improve your experience and enjoyment using our Services;
respond to your comments, questions, and support queries, and provide customer service;
communicate with you about new products and services, upcoming events, promotions, rewards, and other news about products and services offered with the appropriate permission rights;
process and deliver incentives and rewards;
append information about you with consent to compile personal information we get from third parties, to help understand your needs and provide you with better and more personalized service; and protect, investigate, or deter against fraudulent, unauthorized, or illegal activity.
Data is retained per the terms of service and service level agreements in place with our customers, in some cases. The type of information, the purpose for which it is used, and the data category dictate how and when data is purged from our system. Data can also be removed at a user’s request. In general, we will retain anonymous traffic from unknown visitors for twelve (12) months from the launch of our marketing campaigns. VLG owned data may be kept indefinitely when anonymized. Otherwise, data is held only for the length of time reasonably needed to fulfill the obligations outlined in this document.
On Your Device
While you are browsing VLGs websites, your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language and referring Web site addresses may be logged automatically. We may use this information to monitor, develop, and analyze your use of the Service. In addition, we may ask you to submit and we may process data that is personal to you, including but not limited to your name, profile photo, gender, age, birthday, links to your profiles on social networking websites and other third party sites, user names, e-mail and mail addresses. We may use this information to create a user profile and provide you services. With permission, we may use your email address to contact you about your experience with VLG sites and notify you about company news and promotions. Your gender and birthday may be used to analyze user trends and target certain promotions. Your mail address may be used if we have merchandise or other physical promotional materials that we want to send to you. If you no longer wish to receive these types of promotional materials, you may opt-out from receiving them at any time by emailing us at email@example.com.
iOS and Android Platforms
When you use any of the VLG games or applications on a mobile platform, we may collect and record certain information such as your unique device ID (persistent/non-persistent), hardware type, media access control (MAC) address, international mobile equipment identity (IMEI), the version of your operating system (OS), your device name, and your location (based on your Internet Protocol (IP) address). This information is useful to us for troubleshooting and helps us understand usage trends.
Apple Game Center, Amazon Game Circle, and GREE
Our apps can be connected to Apple’s Game Center, Amazon’s Game Circle, and Android-compatible GREE gaming services. These services authenticate your identity and provide you the option to share certain personal information with us and others.
We collect your name, address, phone number, and email address when you make a purchase on vlgmarketing.com or contact us for customer help. You may contact us from time to time. In order to reply, we will likely use your email address or phone number to contact you. If you no longer wish to receive certain email communications from VLG, please opt-out using the links provided at the bottom of each email we send. You can also email us at firstname.lastname@example.org and you won’t be notified of upcoming sales, promotions or other product information.
We may occasionally send our customers’ employees permission-based push notifications through our software, third-party software, or mobile applications. These employees may opt-out of receiving these notifications by turning them off using your device’s built-in notification settings.
Game Data Collection
We collect anonymous data about all of your interactions with the game via server log files and through the use of Google Analytics. This information is aggregated and used to improve our products and features, as well as identify potential bugs in our code.
We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the mobile application.
Third Party Services
How We Use Information
We may use information to provide you genuine customer service, as well as enhanced features and functionality within each app and on our website. In addition, we may collect information for dissemination to VLG customers through the normal course of business.
Disclosure of Your Information
We do not sell your personal information. Our customers are far too important to us and we would not want to betray that trust. That said, VLG collects data and it may be used in the following manner:
We may release your information as permitted by law, such as to comply with a subpoena, or when we believe that release is appropriate to comply with the law; investigate fraud, respond to a government request, enforce or apply our rights; or protect the rights, property, or safety of us or our users, or others. This includes exchanging information with other companies and organizations for fraud protection.
With your permission, we may share information about you with advertisers, publishers, business partners, sponsors, and other third parties.
Changes to the Policy
VLG takes extraordinary measures to protect your information from unauthorized access or against loss, misuse or alteration by third parties. Although we make good faith efforts to store the information collected on the Service in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party hackers from illegally obtaining access to this information. We do not warrant or represent that your information will be protected against loss, misuse, or alteration by third parties. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
Access to Personal Information
We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at email@example.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Our Policy Regarding Children
We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to use our Service. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal information. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 13, please contact us at firstname.lastname@example.org.
Opting Out of Marketing
Individuals located in the European Economic Area will be forced to opt-in if prior approval has not already been obtained by the controller. You may opt-out of receiving promotional emails from us by following the instructions in those emails or by emailing us at email@example.com. If you opt-out of marketing communications, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations. You may also opt-out of receiving SMS notifications from us, either via SMS or by emailing us at firstname.lastname@example.org.
Public Information Technology Accessibility Policy
It is the policy of VLG (the “Company”) that its public website (the “Website”) and any application developed for IOS, Android and similar mobile devices (“Mobile Apps”) used by the public be made accessible to and usable by those with disabilities based on current industry standards, the requirements of the Americans with Disabilities Act and other state and federal accessibility legislation. Implementation of this policy is the responsibility of the Implementation Officer (the “Implementation Officer”) in consultation with the Senior Officer (the “Senior Officer”). The Implementation Officer shall include in each annual, quarterly or other budget proposal an amount specifically allocated to carrying out this Policy. The Implementation Officer is authorized in consultation with a Senior Officer to hire such third-party consultants as may be necessary to carry out this policy.
VLG Marketing LLC (VLG) is firmly committed to compliance with the Americans with Disabilities Act and to ensuring that those with disabilities have meaningful access to all of its products and services, including its website. As part of this commitment, we are continually monitoring accessibility of our website and making improvements as necessary so the website is accessible to and usable by all individuals with disabilities. If you encounter any difficulty accessing our website because of a disability, have suggestions about improving the usability or accessibility of the website for those with disabilities, or would like to know more about VLG’s commitment to accessibility, please contact our accessibility team by email or phone using the contact information below.
For assistance not related to website accessibility for those with disabilities, please call 972-792-9550.
Mobile App Accessibility
VLG is firmly committed to compliance with the Americans with Disabilities Act and to ensuring that those with disabilities have meaningful access to all of its products and services, including its mobile applications. As part of this commitment, we are continually monitoring accessibility of our mobile applications and making improvements as necessary so they are accessible to and usable by all individuals with disabilities. If you encounter any difficulty with the use of our mobile apps because of a disability, have suggestions about improving the usability or accessibility of the website for those with disabilities, or would like to know more about VLG’s commitment to accessibility, please contact our accessibility team by email or phone using the contact information below.
For assistance not related to website accessibility for those with disabilities, please call 972-792-9550.
The Company adopts the Web Content Accessibility Guidelines version 2.1 at Success Level AA as its website accessibility standard. The Company adopts the principles and success criteria of WCAG 2.1 AA as its accessibility standard for Mobile Apps to the extent they apply. Together these are the Company’s Information Technology Accessibility Standard (“ITA Standard”). This standard may be modified as needed to improve usability or as industry and regulatory standards and technologies change.
Initial Accessibility Audit & Initial Plan
No later than September 20, 2021 the Implementation Officer will arrange for an audit of the Website and Mobile Apps using commercially available software tools to identify web pages, individual web page elements, Mobile Apps and app features that do not conform to the ITA Standard.
Based on the results of the Website and Mobile App testing the Implementation Officer will develop and implement a plan (the “Initial Plan”) to correct any website and mobile app accessibility errors identified by this audit no later than November 30, 2021. The Initial Plan will include:
Obtaining certification by all third-party vendors who provide coding, design or other services for the Website and Mobile Apps that they are familiar with the Company’s ITA Standard and in particular with WCAG 2.1, Level AA and the methods for its implementation in the Website and Mobile Apps.
Amending or updating contracts with third party website and application vendors to specify that the ITA Standard is a basic requirement for the Website and Mobile Apps.
Correcting any deficiencies in the Website and Mobile Apps identified by the software tools used.
Creation of a web page with a general statement of The Company’s commitment to website accessibility with email and phone contacts for customers who experience accessibility disabilities. This web page will conform to WCAG 2.1, Success Level AAA. Links to this web page will be placed so that individuals using screen reader technology will be aware of the page when they first access the website and so that all users can easily find a link to this page on every page in the website.
Inclusion of a similar statement and information in an appropriate place within each Mobile App.
Creation and implementation of a procedure for prompt response to consumer complaints concerning accessibility of the Website and Mobile Apps.
Appropriate training of The Company’s information technology staff in the requirements of the ITA Standard and this Policy, with the first training to be completed for all web development staff no later than November 30, 2021.
Quarterly reporting to Senior Officer concerning the status of implementation of this Policy.
Ongoing Accessibility Audit & Initial Plan
No later than January 31, 2022 the Implementation Officer will retain one or more third-party consultants and with those consultants develop a plan to conduct a user-based audit of the Website and Mobile Apps and correct any remaining errors necessary to make the Website and all Mobile Apps accessible based on the ITA Standard. This Final Accessibility Plan shall describe in reasonable detail how the Company will accomplish these goals by March 31, 2022.
In addition, the Final Accessibility Plan will include provisions for the following:
Ensuring that any newly installed third-party plug-ins used in the Website substantially conform to WCAG 2.1, Level AA and, no later than 36 months from the date of the plan, and replacing all existing third-party plug-ins with WCAG 2.1, Level AA conforming plug-ins.
Regular testing of the Website and Mobile Apps with commercially available software tools to determine whether they meet the requirements of the ITA Standard.
Prompt correction of any deficiencies found by such testing.
Inclusion in all contracts for development or maintenance of the Website or Mobile Apps a warranty that the work performed properly implements the ITA Standard.
Provision for Changing Technologies
The Implementation Officer will survey changing accessibility technologies and standards at least once every two years and make such changes in the Final Accessibility Plan and this Policy as may be needed to improve the accessibility of the website and comply with any applicable governmental regulations.
In order to receive further information regarding use of the Site or to resolve a complaint regarding the Site, please contact us at:
VLG Marketing LLC
16750 Westgrove Drive
Addison, TX 75001