Privacy Policy

Contents

I. What does this Privacy Policy cover?

II. What types of information does VAE collect?

III. From what sources does VAE collect Personal Information?

IV. What third parties collect Personal Information on behalf of VAE ?

V. For what purposes does VAE collect Personal Information?

VI. With whom does VAE share Personal Information?

VII. How does VAE treat Personal Information transferred out of the EU?

VIII. How is my Personal Information protected?

IX. What rights do you have to your Personal Information?

X. How does VAE use cookies and other identifiers?

XI. Are there any special categories related to Personal Information?

XII. How will VAE notify users of changes to this Privacy Policy?

XIII. How can someone contact VAE ?

 

LAST UPDATED: 08/01/2022

 

PRIVACY POLICY

 

We at VAE work hard to provide onlineservices and mobile gaming experiences. With so many individuals logging into and connecting through our games, we understand the importance of your privacy. Maintaining your privacy and the trust of our users is important to us. VAE may store, process, and, under certain circumstances, share your information as described in this Privacy Policy.

 

Throughout this Privacy Policy we refer to “Services,” which means our websites, games, surveys, promotions, contests, purchases, community support, and related activities.

 

I. What does this Privacy Policy cover?

This Privacy Policy describes how we process Personal Information (defined below) about individuals and households that: (1) play our games, (2) interface with activities we undertake to support our games (e.g., promotions, contests, advertising campaigns, etc.), and (3) use our website and related third-party tools to apply for jobs with us.

It only applies to VAE’s websites, services, products and offerings. It does not apply to other non-VAE service providers and websites, including those to which we may link – those websites, services or games will have their own privacy policies, which we encourage you to review and understand.

This Privacy Policy describes our processing and practices related to your Personal Information. By using our Services, you are confirming that you understand English well enough to understand this Policy. Should you have questions about this Policy, please contact us as described below, so we can clarify and address your questions.

 

II. What types of information does VAE collect?

We may collect different types of information from you depending on how you use our Services, including Personal Information. “Personal Information” means information that relates to an identified or identifiable natural person.

Examples of Personal Information we may collect include:

Ø    Full name

Ø    Date of birth

Ø    Email address(es)

Ø    Phone number

Ø    Age

Ø    Language and other information about location

Ø    Photographs

Ø    Social media account (e.g., Twitter handle, Facebook account, etc.) identifiers created by third-party platforms used to download and/or access our games

Ø    Influencer and social media channels

Ø    Billing, payment, and financial data

Ø    Account information such as account name, account identification number, external account key, account activity, and account change activity

Ø    In-game and external purchase/transactions history

Ø    Contest entry information

Ø    Gaming activity information such as in-game ID, character name, display name, gameplay history, friend lists, friend requests, and in-game communications

Ø    Game identifiers

Ø    Game file version

Ø    Device ID, Device Key, MAC address, and IP address

Ø    Computer operating system and system specifications

Ø    Mobile OS Version and certain information concerning devices you use to access the Services

Ø    GeoIP information

Ø    Internet browser provider and type

Ø    Your “click path” and pages visited on our websites

Ø    The advertisement, website or link that brought you to one of our websites and any site visited immediately after leaving one of our websites

Ø    Marketing information such as mailings receiving, mailings opened, sign-up information

In addition to the above, we may also collect information that does not generally identify you but may become associated with your account. We reserve the right to use information that does not generally identify you in connection with any lawful purpose.

 

III. From what sources does VAE collect Personal Information?

 

A. From you

We may collect your Personal Information when you provide it to us directly through the Services you use, for example when you:

1. Register for an account, contest or giveaway

2. Submit additional information on the account page or when otherwise prompted by us

3. Order products

4. Send email messages, submit forms, or contact us

5. Respond to surveys or customer questionnaires

6. Report a problem with the Services

7. Play games

8. Register for or participate in an event

 

B. From Third Parties

We also may receive Personal Information from or through certain third-party services that help us provide the Services and/or facilitate your access to the Services, including, by way of example, third-party platforms that you may use to log in and access our Services (e.g., Facebook, Google, Game Center) and the third-party services described in Section IV of this Privacy Policy (e.g., payment processors and advertising partners).

We abide by this Privacy Policy when we use Personal Information provided to us by third parties. However, we do not control the information that these third parties collect or how they use that information. You should review these third parties' privacy policies for more information about how they collect, use, and share information they obtain and use, including the information they may disclose to us if you use their service credentials to log in to our Services.

 

IV. What third parties collect Personal Information on behalf of VAE?

 

A. Payment Processors

For security reasons and to better protect your privacy, we do not directly collect or store your payment information and are only able to access limited information concerning payment method and transactions. Should you choose to make financial transactions through our Services, we use third-party payment processors who collect payment information on our behalf to process your transactions. Specifically, payment, billing and credit card verification services may need to collect certain Personal Information in order to access your payment methods and process your transactions. If you choose not to provide Personal Information for payment processing needs, they will not be able to complete your requested transaction(s) on our behalf.

 

B. Advertising and Attribution Partners

We may receive Personal Information about you from third-party advertising partners that manage advertising campaigns on our behalf.

For example, if you click on an advertisement that directs you to one of our Services (such as a banner advertisement located on a third-party website), we may receive information concerning the advertisement, website or link that brought you to one of our websites and the applicable ad campaign. We may also receive Personal Information about you from third-party attribution partners that help us understand the efficacy of our campaigns.

For example, if you click on an advertisement that directs you to one of our Services (such as a banner advertisement located on a third-party website), we may receive information such as your subsequent account creation, downloads, and purchases.

 

C. Customer Support Partners

We may use third-party customer service platforms that help us provide support to our users by offering them a means by which they may contact us with inquiries about our Services. Some of these customer service platforms may provide us with certain Personal Information (e.g., email address) of users that reach out for support.

 

D. Fraud Protection and Authentication Service Providers

Fraud protection and authentication service providers may collect Personal Information on our behalf concerning the devices and game play of our users. This information may be collected when users log in to one of our websites or play one of our games. This information may be used to help us maintain the integrity of our Services, and support our anti-fraud and anti-cheating efforts.

 

E. GeoIP Location Service Providers

GeoIP location service providers may collect information for us about the location of our users. This may be collected when a user logs in to one of our Services. This information may be used to help keep the Services more secure and create a more customized experience for our users.

 

V. For what purposes does VAE collect Personal Information?

The following provides examples of the purposes for which we may use your Personal Information:

 

Context

Types of Data

Primary Purpose for Collection
and Use of Data

Account Activity

We collect information such as your name, contact information, and game-related information when you create an account. We also collect information relating to the actions that you perform while logged into your account.

We use this information to perform our contract to provide you with products or services. We also have a legitimate interest in providing account related functionalities to our users. Accounts can be used to save your preferences, game play, and transaction history. We also have a legitimate interest in understanding the efficacy of our marketing campaigns. In limited circumstances, we may use this information to protect the vital interests of you or another person.

Testing/Early Access Programs

We collect Personal Information as part of our testing, early access, and similar programs.

We have a legitimate interest in making sure our products are secure and error free. We may also use this information to perform our contract to provide you with products or services.

Communications

When you communicate through a Service, even privately, we process, store, and may monitor those communications to detect cheating, fraud, illegal activity, or other activities that may violate one of our User Agreements.

We have a legitimate interest in ensuring the security of our Services and detecting illegal activity. We also have a legitimate interest in responding to communications that we receive. In limited circumstances, we may use this information to protect the vital interests of you or another person.

Cookies and first party tracking

We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed. See our Cookie Policy for more information.

We have a legitimate interest in making our website operate efficiently.

Cookies and Third Party Tracking

We use cookies and other tracking technologies to collect analytics information about your use of our Services. We also participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites.

Where required by law, we base the use of third party cookies upon consent.

Demographic Information

We collect information such as your age or location.

We use this information to ensure compliance with our User Agreements. We also have a legitimate interest in understanding our users and providing tailored services.

Distance Information

When you use our Services, we may collect your location from the GPS, Wi-Fi, and/or cellular technology in your device to determine your location.

We have a legitimate interest in keeping our Services secure, understanding our users, providing tailored services, and detecting and preventing fraud or illegal activity. In some contexts our use is also based upon your consent to provide us with geo location information.

Email Interconnectivity

If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.

We have a legitimate interest in understanding how you interact with our communications to you.

Feedback/Support

If you provide us feedback or contact us for support, we will collect your name and e-mail address, as well as any other content that you send to us, in order to process your inquiry and/or reply to you. We may also use your billing data to processes returns and chargeback requests.

We have a legitimate interest in receiving, and acting upon, your feedback or issues. In some circumstances, we use your information to perform our contract to provide you with products or services.

Gameplay

We collect your Personal Information such as, but not limited to, contact information, social media profile information, and in-game activity logs to provide you with our games.

We use this information to perform our contract to provide you with products or services. We also have a legitimate interest in optimizing our users’ experience, identifying and fixing program bugs and errors, and preventing fraud and cheating.

Influencer Interactions

We collect Personal Information from influencers who play our games or otherwise support our promotions.

We use this information to perform our contract with influencers. We also have a legitimate interest in understanding how influencers interact with our games, customers, and promotions.

Live Events

We collect Personal Information from participants at our live events.

We have a legitimate interest in detecting and preventing fraud and illegal activity, understanding our users, and hosting live events.

Mailing List

When you sign up for one of our mailing lists, we collect information such as your email address, event participation, and/or other information that allows us to communicate with you.

We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services.

Mobile Devices

We may collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website.

We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.

Order Placement

We collect your name, billing address, shipping address, e-mail address, phone number, and credit card number when you place an order or purchase in-game products or services.

We use your information to perform our contract to provide you with products or services. We also use this information to detect and prevent fraud or other illegal activity. In some cases, we have a legitimate interest in understanding the efficacy of our new user acquisition campaigns.

Sweepstakes or contests

When you participate in a sweepstakes or contest, we collect information about you which includes contact information to notify you if you are selected. We may also collect information such as your social security number in order to confirm your eligibility for certain prizes and process winnings.

We have a legitimate interest in operating the sweepstakes. In some contexts, we are also required by law to collect information about those that enter into our sweepstakes, and we have a legitimate interest in complying with those laws.

Third Party and Social Media Account Information

We may collect third party and social media account information (e.g., SteamID, Facebook information, etc.) to log you in. We may also use this information to respond to your communications through third party platforms.

We use your information to perform our contract to provide you with products or services. We also have a legitimate interest in allowing users the ability to log in and communicate with us through multiple gaming platforms.

Website interactions

We use technology to monitor how you interact with our Services. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.

We have a legitimate interest in understanding how you interact with our Services to better improve it, to understand your preferences and interests in order to select and provide offerings that you might prefer, and to understand the efficacy of our marketing campaigns. We also have a legitimate interest in detecting and preventing fraud, and detecting and fixing program bugs and errors.

Web logs

We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.

We have a legitimate interest in monitoring our networks and the visitors to our Services. Among other things, it helps us detect and fix program bugs and errors.

 

VI. With whom does VAE share Personal Information?

A. Third-Party Vendors

We do not share Personal Information with third parties for their direct marketing purposes; however, we may share your Personal Information with third-party vendors that are subject to contractual and legal limitations on how they may use Personal Information they process.

These limitations generally prohibit vendors from using Personal Information for any purpose other than the purpose for which it was provided or collected. When we share Personal Information with vendors, we do so to provide you with access to our Services and to administer, improve, present, and market our Services and business.

The categories of third-party vendors that we may disclose Personal Information to include the following:

Ø     Fraud detection and management services, authentication services, and vendors that assist us with managing other risks associated with our business

Ø     Customer support and localization (i.e., translation) vendors

Ø     Marketing and advertising platforms and marketing companies, including vendors that help us manage contests, sweepstakes, surveys, and similar promotional events

Ø     Customer attribution services

Ø     Cloud-based recruitment vendors that assist us with processing job applications and other related recruitment activities

Ø     Social media websites and email providers

Ø     Moderation and user experience providers

Ø     Fulfillment houses

Ø     Consultants, attorneys and similar vendors that are obligated to keep Personal Information secure and confidential and use it only for the purposes for which we disclose it to them

 

B. Other Parties

We may also disclose your Personal Information in the following circumstances:

We may disclose your Personal Information to law enforcement or other appropriate third parties in connection with criminal, fraud, infringement, other investigations related to suspected illegal activities, to protect the health and safety of our players, personnel or third parties, as may be required or allowed by applicable law, or to protect the legitimate legal and business interests of VAE, our personnel and customers.

We may disclose your Personal Information where necessary to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.

We may disclose your Personal Information to our subsidiaries and affiliates. For example, this may occur where an affiliate’s personnel provide support in connection with offering one of the Services or where there is a reallocation of organizational resources among our affiliated entities.

We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.

 

VII. How does VAE treat Personal Information transferred out of the EU?

A. Place of Business

We may store or process your Personal Information outside of the country where we collect it or which you reside. VAE has its primary places of business in the Commonwealth of Australia.

If you use one of our games, and reside outside the Commonwealth of Australia, you should understand that you are choosing to transmit your data to us in the Commonwealth of Australia, and that the Commonwealth of Australia may not offer the same level of privacy protection as your own country.

Specifically, there may be situations in which we are required to provide the personal information that you transmit to us to law enforcement agencies in the Commonwealth of Australia.

 

B. Transfer Mechanisms

If you are located in the Commonwealth of Australia and choose to transfer personal information to us in the Commonwealth of Australia by playing one of our video games that is hosted in the Commonwealth of Australia you are making a decision to transfer your data to a country that may not offer the same level of privacy protections as your own country.

When we transfer Personal Information that we collected in the EU or the UK outside of Commonwealth of Australia we implement technical, organizational, and physical safeguards to protect that Personal Information. When transferring data outside of the Commonwealth of Australia, we currently rely upon European Commission approved standard contractual clauses.

Please contact us if you have questions related to the relevant transfer mechanism for your Personal Information.

C. Privacy Shield

VAE complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union and Switzerland to the United States.

VAE is responsible for the processing of the Personal Information we receive and subsequently transfer to a third party acting as an agent on our behalf, and we remain liable if a third party acting on our behalf uses your Personal Information in a way that is inconsistent with our obligations under Privacy Shield, unless we can prove that we are not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, VAE commits to resolve complaints about our collection or use of your Personal Information. European Union or Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact VAE using the information found at the end of this Privacy Policy. VAE commits to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner and comply with the advice given by the panel and Commissioner about Personal Information transferred from the EU or Switzerland.

The Federal Trade Commission has jurisdiction over VAE ’s compliance with the Privacy Shield. You may have the right, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. See https://www.privacyshield.gov/article?id=ANNEX-I-introduction for more information.

 

VIII. How is my Personal Information protected?

 

A. Our Retention, Purpose Limitation, and Security Policies

We protect your Personal Information through a combination of collection, security, and retention policies.

1. Limited Retention. We only keep your Personal Information for as long as we need it for business and operational needs or to comply with any statutory, regulatory, or legal obligations.

2. Purpose limitation. We will use your Personal Information only for the Services you choose to access and for the purposes for which you choose to share it. We will respect your requests to start or stop processing your Personal Information for marketing purposes, as well as the types of marketing messages you may wish to receive.

3. Security Measures. We use appropriate measures to keep the Personal Information we collect and use in a secure environment, and we have implemented technical, administrative, and physical security measures designed to protect Personal Information from unauthorized access, disclosure, use, and modification. As part of our privacy compliance processes, we review these security procedures on an ongoing basis to consider new technology and methods as necessary. However, please understand that our implementation of security measures as described in this Privacy Policy does not guarantee the security of your Personal Information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

 

B. Your Practices and Activities

Your practices and activities are likewise very important in the protection of your own Personal Information. You can take certain steps to help protect your Personal Information, such as being mindful of what you post in public places.

1. Do not use your real name when selecting a username. Your username will be available to the internet's general public while you participate in some Services, like forums, chat rooms, or message boards, so you should exercise your own discretion when using these Services.

2. Do not post your real name in public-facing areas of the Services, such as forums, chat rooms, or message boards, and do not share anything private about yourself on such public platforms, including your phone number or address. Use usernames instead of real names at all times.

3. Many types of communications, especially those on public forums or social media, are generally available to the public or large groups of unknown users. Remember that we have no control over what third parties do with the content of such communications and no responsibility or obligation regarding third parties’ collection or use of communications you share. To the extent that you are create a public profile that may be available to others on our Services, you are solely responsible for its content at all times.

 

IX. What rights do you have to your Personal Information?

 

A. Right to Access, Correct, Delete, or Restrict Processing

Subject to any limitations under applicable law, you may be able to exercise a number of rights:

You may have the right to request access to your Personal Information, including in a portable format.

You may have the right to correct or update certain types of Personal Information. In many cases, you can review or update the Personal Information in your account by accessing your account online.

You may have the right to request deletion of your account and related Personal Information. If you choose to have your Personal Information removed from our active databases, we will carry out your request within 30 days of account verification and will only retain minimal information to document your request and the actions we took to carry out your request.

You may have the right to restrict certain processing of your Personal Information, and the right to object to some types of processing of your Personal Information.

You may have the right to object to your Personal Information being used for marketing or advertising purposes.

We will comply with your rights requests in accordance with, and subject to, applicable law. Please note that we are legally prohibited from carrying out requested actions in some instances, including (1) when we are unable to confirm your identity; (2) where the request is considered excessive, and (3) where doing so would adversely affect the rights or freedoms of other individuals.

 

B. We are here to help

Please contact us at [email protected]or using the contact information provided in Section XIII of this Privacy Policy if you would like to exercise any of the rights described above, if you have questions regarding your rights, or if you would like to appeal a decision we made regarding your rights.

You may also be able to submit a rights request through online forms provided on our support pages or through the request portal that is available after you have logged into your account. For assistance with our online request portals, please send an email to sal[email protected].

You also have the right to contact our data protection officer (DPO) if you are unsatisfied with how your request is being handled. To get in touch with him or her for any information concerning our processing of Personal Information, please contact: [email protected].

 

C. Right to Lodge a Complaint

You have the right to lodge a complaint regarding our collection, processing, or storage of your Personal Information with a data protection supervisory authority in the country where you live or work.

 

X. How does VAE use cookies and other identifiers?

 

A. Cookies and Tracking Pixels

When you visit one of our websites, we may ask your browser to store a “cookie”, which is a small text file, on your device to remember information about you, such as your language preference or login information.

We and our third-party providers use cookies to assign a unique number that automatically identifies your computer when you visit our websites. Some cookies remain on your computer until you delete them; others, like session ID cookies, expire when you close your browser.

We and our third-party providers also use other identifiers (such as Clear GIFs, pixels, web beacons) to track the pages visited on our websites or the emails and other communication we send.

Such tracking identifiers are tiny graphics that are embedded invisibly on web pages or in HTML-based emails. Please be aware that we do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.

 

B. Purposes

We use cookies and other tracking technologies for the following purposes:

1. To assist you in navigating our websites or to display certain types of content;

2. To assist you in registration for our events, to log in to certain features or to provide us your feedback;

3. Analyzing your use of our Services, functionality and use of our pages and links, collecting aggregated user data, and traffic sources; and

4. Tracking and analyzing our promotional and marketing efforts.

 

C. Third Party Cookies

Some cookies on our websites come from third-party advertisers or analytics providers. These cookies improve your experience by helping us better tailor our websites and our marketing campaigns to our audience.

We work with third-party advertising and analytics providers to help collect information about website visitors and account holders and their usage of our Services. Those third-party providers may use cookies and tracking identifiers to collect, and may otherwise have access to, information about users of our Services, including Personal Information.

For example, third-party providers may collect or otherwise have access to usage information (e.g., information about the pages where users enter and exit our websites, what pages they view on our websites, etc.), device information, online identifiers of users, and demographic and interest-level information.

 

D. Facebook Tracking Pixel

Our websites may use the Facebook Tracking Pixel, which is a service of Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304. The Facebook Tracking Pixel allows us to provide you with targeted ads based on your prior use of our Services, and your interaction with the social network Facebook.

The information collected by Facebook in connection with your use of our websites is transmitted to a Facebook server in the US, where it is stored and analyzed. For information about how Facebook Tracking Pixel collects and processes data, please see the following link: https://www.facebook.com/about/privacy.

Facebook’s collection and use of information is subject to Facebook’s Privacy Policy. If you would like to opt out of Facebook tracking, you can adjust your browser settings to not accept cookies. Note that, by changing your browser settings, you may still receive ads, but they may not be targeted.

 

E. Google Analytics

We use Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, US. On a de-identified basis, Google analyzes your use of our websites on our behalf.

The information collected by Google in connection with your use of our websites is transmitted to a server of Google in the US, where it is stored and analyzed. For information about how Google Analytics collects and processes data, please see the following link: https://www.google.com/policies/privacy/partners/. Google’s collection and use of information is subject to Google’s Privacy Policy. If you would like to opt out of Google Analytics tracking, please visit one of the following links:

1. Google Ads Settings (http://www.google.com/settings/ads), or

2. the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout/)

 

F. Google Campaign Manager

Our websites may use Campaign Manager (formerly Doubleclick) by Google. Campaign Manager serves cookies to help us display relevant advertisements to our users, understand the performance of our ad campaigns, and prevent users from seeing the same ad multiple times.

These cookies may collect information about your actions and otherwise track your behavior on third-party websites, including conversions related to ad requests. If you would like to opt out of Google Campaign Manager tracking, you can install the appropriate plugin for your browser (if you use Chrome, Firefox or Internet Explorer) by following this link and/or adjust your browser settings to not accept cookies. Note that, by installing the plugin or changing your browser settings, you may still receive ads, but they may not be targeted.

 

G. Youtube

Our websites may use Youtube to store and show video content. Youtube serves cookies to help us provide the video content, but does not collect or process your information for advertising or analytics purposes.

 

H. Unity Ads

In some of our or our affiliates’ Services, we may use Unity Ads, an advertising service offered by Unity Technologies, 30 3rd Street, San Francisco, CA 94103 and Unity Technologies Finland OY, Kaivokatu 8 B, 00100 Helsinki, Finland. We do not send Unity Ads your Personal Information. Rather, Unity Ads collects Personal Information directly from your device, and uses this Personal Information to provide you targeted advertising. You can view their privacy policy, which includes instructions on how to restrict the collection of Personal Information, by visiting their website (https://unity3d.com/legal/privacy-policy).

 

I. Other Third Party Tracking Cookies

In addition to the third party cookies listed elsewhere in this policy, we may use tracking cookies from other companies to tailor our advertising to our users and create a more personalized experience for them.

 

J. Browser Settings; Choices about Cookies

You may set your browser setting to attempt to reject the cookies and tracking identifiers, and you may still use our websites. However, you may be limited in some areas of our websites, or you may have to enter passwords or identifying information more than once.

As discussed above, we may use cookies and other tracking identifiers to collect information about your online activities over time and across third-party websites or other online services. Click here for information on how you may be able to opt out of tracking and mechanisms that may enable consumers to exercise choice about tracking.

 

XI. Are there any special categories related to Personal Information?

 

A. Minors

1. Our Services are not designed for children, and we do not intentionally collect, maintain, or disclose any Personal Information from children. A “child” is usually considered to be under the age of 13 under applicable law; however, depending on where you live, the age which a person receives special protections for their data may be higher.

2. If you are a parent or guardian of a child who has submitted Personal Information, you can request removal by sending us an email at [email protected]. If you do so, please provide the same username and email address that your child submitted. If your child has used your credit card on our Services without your permission, please contact us immediately at [email protected].

 

B. California

1. We provide registered users the ability to post information on our Services. If you are a California resident who is under 18 and a registered user and you are unable to remove content or information you posted in a public area following the instructions provided, you may request removal by contacting us.

When requesting removal, you must be specific about the information or content you want to remove and provide the URL for each place it is located. We are not required to remove any content or information that: (a) we, or a third party, are legally required to maintain; (b) was not posted by you; (c) is anonymized so that you are not identified; (d) is not based on a request that follows our instructions for removing or requesting removal; or (e) you received compensation or other consideration for providing the content or information.

2. California Civil Code Section 1798.83 permits California residents to request information from us concerning any disclosures of Personal Information we may have made in the prior calendar year to third parties for direct marketing purposes. If you are a California resident and you wish to request information about our compliance with this law or our privacy practices, please contact us at [email protected].

3. If you are a California resident, the California Consumer Privacy Act of 2018 (“CCPA”) requires us to provide you with additional information concerning our use of your Personal Information:

I. In the preceding 12 months, VAE has not sold Personal Information. VAE only shares Personal Information with service providers.

II. In the preceding 12 months, VAE has collected and disclosed the following categories of Personal Information for a business purpose:

           

Categories of Personal Information We Collect

To Whom We May Disclose Personal Information for a Business Purpose

Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, social security number, driver’s license number, passport number or other similar identifiers.

· Advertising networks

· Affiliates or subsidiaries

· Business partners

· Data analytics providers

· Government entities, as may be needed to comply with law or prevent illegal activity or harm

· Internet service providers

· Operating systems and platforms

· Other Service Providers

· Payment processors and financial institutions

· Professional services organizations, this may include auditors and law firms

· Social networks

Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information.

· Affiliates or subsidiaries

· Business partners

· Government entities, as may be needed to comply with law or prevent illegal activity

· Other Service Providers

· Payment processors and financial institutions

· Professional services organizations, this may include auditors and law firms

Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical or mental handicap, etc.

· Affiliates or subsidiaries

· Business partners

· Government entities, as may be needed to comply with law or prevent illegal activity

· Internet service providers

· Operating systems and platforms

· Other Service Providers

· Professional services organizations, this may include auditors and law firms

Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

· Advertising networks

· Affiliates or subsidiaries

· Business partners

· Data analytics providers

· Government entities, as may be needed to comply with law or prevent illegal activity

· Internet service providers

· Joint marketing partners

· Operating systems and platforms

· Other Service Providers

· Payment processors and financial institutions

· Professional services organizations, this may include auditors and law firms

· Social networks

Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.

· Advertising networks

· Affiliates or subsidiaries

· Business partners

· Data analytics providers

· Government entities, as may be needed to comply with law or prevent illegal activity

· Internet service providers

· Operating systems and platforms

· Other Service Providers

· Professional services organizations, this may include auditors and law firms

· Social networks

Geolocation data

· Advertising networks

· Affiliates or subsidiaries

· Business partners

· Data analytics providers

· Government entities, as may be needed to comply with law or prevent illegal activity

· Internet service providers

· Operating systems and platforms

· Other Service Providers

· Professional services organizations, this may include auditors and law firms

Audio, electronic, visual, thermal, olfactory, or similar information

· Affiliates or subsidiaries

· Business partners

· Data analytics providers

· Government entities, as may be needed to comply with law or prevent illegal activity

· Internet service providers

· Operating systems and platforms

· Other Service Providers

· Professional services organizations, this may include auditors and law firms

Inferences drawn from any of the information listed above

· Advertising networks

· Affiliates or subsidiaries

· Business partners

· Data analytics providers

· Government entities, as may be needed to comply with law or prevent illegal activity

· Internet service providers

· Operating systems and platforms

· Other Service Providers

· Professional services organizations, this may include auditors and law firms

· Social networks

 

4. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing your request to [email protected]. You may also be able to submit a rights request through online forms provided on our support pages or through the request portal that is available after you have logged into your account. For assistance with our online request portals, please send an email to [email protected].

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. To submit a verifiable consumer request, you must

Ø    Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of a person about whom we collected Personal Information; and

Ø    Describe your request with enough detail to allow us to properly understand, evaluate, and respond to the request.

Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name, the last item you purchased from us, or the date of your last purchase from us. We may also ask you to provide a signed declaration confirming your identity. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you or the person on whose behalf you are making the request. We will only use Personal Information provided in a consumer request to verify the requestor's identity or authority to make the request.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf.       You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual you must reach out to [email protected] for a copy of our Authorized Agent Designation Form and additional instructions. All requests that do not comply with these procedures will be denied.

To be clear – any disclosures we provide in response to a verifiable consumer request will only cover the 12-month period preceding the verifiable consumer request’s receipt.

If we cannot comply with a request (including where we cannot verify it), we will explain the reasons we cannot comply with a request.

We will take steps to respond to a verifiable consumer request within 45 days after we receive it. If we require more time to respond, we will inform you of the reason for the delay and extension period in writing. We will deliver our written response by mail or via email, at your option.

For data portability requests, we will choose a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

5. We will not discriminate against you for exercising any of your rights described in this Section XI(B). Unless permitted by the CCPA, we will not:

Ø  Deny you goods or services.

Ø  Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

Ø  Provide you a different level or quality of goods or services.

Ø  Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, to the extent permitted by CCPA, we may offer you certain financial incentives that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your Personal Information and contain written terms that describe the program’s material aspects. Participation in a financial incentive program, if we offer one, requires you to opt-in in advance, and you may opt out at any time.

 

XII. How will VAE notify users of changes to this Privacy Policy?

VAE reserves the right to change this Privacy Policy at any time. To the extent that the Privacy Policy changes in a material way, we will make reasonable efforts to take steps to notify you of such changes.

Additionally, the policy that was in place at the time that you submitted personal information to us will generally govern that information. Our Privacy Policy includes a “last updated” date, which refers to the date that the current version was last substantively modified.

All changes to the Privacy Policy will be effective when posted, and your continued use of any of the Services after the posting will be subject to the updated Privacy Policy.

 

XIII. How can someone contact VAE ?

 

For VAE our mailing address is:

52 Newell st, Footscray, vic 3011, Australia

Our customer service email address is [email protected].

Our privacy email is [email protected].