Privacy Policy
Effective Date: April 30, 2023
Privacy is important to The Verticale. The following describes the information we collect and the ways we use that information. By using https://www.theverticale.com/(the “Website”) and engaging with our services (collectively, the “Services”), you are consenting to the collection, use, sharing, and storage of your personal information, as described below. This Privacy Policy supplements and is incorporated into our Terms of Service which, together with this Privacy Policy and our other online policies, govern your use of the Services. We have endeavored to make this Privacy Policy as clear as possible. If, however, you have any questions, comments or concerns about this Privacy Policy, please send us an email at Hello@theverticale.com.
The terms “The Verticale” or “us” or “we” or “our” refer to The Verticale, Inc., the owner of the Services. The terms “you” or “your” refer to the user or viewer of the Services.
1. Information We Collect. We collect information from those who visit and interact with our Services. This information may include: full name, email address, physical address, and phone number, interests, comments, requests, and other information you may offer. We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. We do not process sensitive information. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. We may receive certain information from data analytics providers regarding usage of the Services and certain transaction information from our brand partners to confirm our referral commission. We generally do not store this information in a manner that identifies individual persons.
The categories of personal information we collect depend on whether you are a user, or visitor, and the requirements of then-applicable law (collectively, “Personal Information”). We may also automatically collect other information as you interact with the Services. We may collect and maintain device, browser, and operating system information, your Internet Protocol (“IP”) address, Services visits, page response times, download errors, length of visits to certain pages, and page interaction information (such as swipes, share lists, and recommendations). We also may automatically collect information from cookies that are placed throughout the Services. Generally, this information is collected in aggregate form, which means we cannot personally identify you through these mechanisms. We may also automatically collect other information as you interact with the Services. We may collect and maintain device, browser, and operating system information, your Internet Protocol (“IP”) address, Services visits, page response times, download errors, length of visits to certain pages, and page interaction information (such as swipes, share lists, and recommendations). We also may automatically collect information from cookies that are placed throughout the Services. Generally, this information is collected in aggregate form, which means we cannot personally identify you through these mechanisms. The above information may also be collected by third-party service providers, such as Shopify/or any other Third Party Entity.
2. How we collect information. We collect certain information using the following technologies:“Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org. We may use cookies and similar tracking technologies to access or store information. By using the Services, you consent to our use of such cookies and tracking technologies.
“Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps. “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.
3. How do we use your personal information? We use this information to facilitate the provision of your requested services. We also use this information to track user behavior, improve our products and services, communicate with you regarding the Services, and generate statistics and trend data for internal and external business purposes, such as marketing campaigns and social media advertising. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more. We may process your information so you can create and log in to your account, as well as keep your account in working order. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.
4. How long do we keep your information? We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, 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 and isolate it from any further processing until deletion is possible.
5. Sharing your Personal Information. We do not share your information for commercial purposes. However, we may share your information in the following ways:
To Other Users: If we allow users to post content on our Services, any personal information may be shared with other users. We are not responsible for how other users use your personal information provided in any posted content.
To Brands and Merchants: Our Services allow independent brands and merchants to offer their products for sale (“Brands”). If you decide to purchase a product through our Services, you direct us to send your personal information to the Brands for processing in connection with their privacy policy. You should review the Brands’ privacy policy before making a purchase. We are not responsible for how Brands use your personal information.
With Vendors, consultants and service providers: We may share your information with third parties that perform tasks on our behalf and that help us better provide our Services to you.
To protect us, our users, or to law enforcement officials: We may share your information to comply with legal processes (including to comply with the law, to enforce our Terms of Service, or to respond to subpoenas, discovery requests, or similar legal processes or proceedings), cooperate with law enforcement or when we believe it is prudent to share information with legal authorities, and investigate and prevent fraud or imminent harm to you, our users, or to us. We may also share your information to ensure the security of our network and services.
In the event of a business transfer: We may share your information with another entity as a result of a corporate sale, merger, consolidation, asset sale, or in the unlikely event of bankruptcy or we go out of business. User information is generally considered an asset that is transferred in one of these types of corporate transactions.
With your consent: We may also share your information in other circumstances when we have obtained your consent.
6. Consent to Data Processing in the United States. Whether you are a resident of the United States, the European Economic Area, or any other global jurisdiction, we may send and store your personal information outside of the country in which you reside. We currently store your data in the United States. By using our Services and consenting to this Privacy Policy, you agree and hereby consent to the storage and processing of your Personal Data in the United States. If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in this Policy. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
7. Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
8. DO-NOT-TRACK. Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage we are not required to honor such DNT signals. If we become subject to requirements to honor DNT signals, we will inform you about that practice in a revised version of this privacy notice.
9. Third Parties. Your information may be held by third parties or we may link to other sites or applications not affiliated, owned, or controlled by us. When you click on a link or an advertisement, you will be directed to that third party’s website. The fact that we link to a third party’s website or advertisement does not in any way create a relationship between us and that third party. We do not endorse or represent any third parties. The privacy practices of any third parties are outside the scope of this Privacy Policy and their use or disclosure of your information (including your personal information) will be governed by their own privacy practices or policies. We encourage you to review the privacy practices or policies of those third parties.
10. Behavioral Advertising. As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
11. Google Analytics and Advertising. We use Google Analytics to better understand how users interact with the Platform. For information on Google Analytics’ information handling practices and how you can control the use of information sent to Google, please visit: www.google.com/policies/privacy/partners/. To disable Google Analytics, please download and install the Google Analytics Opt-out Browser Add-On, which is available here: https://tools.google.com/dlpage/gaoptout/. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick or Google Dynamic Remarketing advertising cookie) together to inform, optimize, and display advertisements based on your past visits to the Platform. You may control your advertising preferences or opt out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at: https://google.com/ads/preferences or by visiting the NAI opt-out tool linked to above.
12. Your Rights. If you would like to access, modify, or delete your personal information, you may submit a request to Hello@theverticale.com. For more information or to see if these rights apply to you, please contact us. We will promptly review all such requests in accordance with applicable laws. Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.
13. Data Retention. When you place an order through the Site, we will maintain your order information, including all provided Personal Information, for our records unless and until you ask us to delete this information.
14. Security. The security of your information is important to us. We maintain various safeguards in order to keep your personal information safe. We always strive to do our best to protect your information, but we cannot guarantee that your information will always be secure. However, you can play your part in ensuring your information remains secure. You should never disclose your login credentials or personal information with anyone else, and you should keep such information in a safe and confidential manner. You should also adopt passwords that are hard to decipher and be sure to log out of your account whenever it is not being used by you. We will notify you, by email or through the Services, if we believe your information has been breached. Such notification will be made to you as soon as practically possible given our need to determine the scope of such breach and to comply with the needs of law enforcement. Please note that you transmit your personal information at your own risk and that we are not responsible for any deliberate or accidental circumvention of our privacy and security measures.
15. Children’s Online Privacy Protection Act. The Services are intended for general audiences and is not directed to children under 13 years old. We do not target this Services to children under 13, and we do not intentionally collect any information from users under 13. If you become aware that your child has used the Services, and we may have personal information about a user under 13, please contact us at Hello@theverticale.com, so we may delete the information.
16. Cookies. Cookies are small bits of electronic information that a website or application sends to your browser and are stored on your hard drive. We use cookies to identify users, track your behavior on the Website, keep the Services secure, and improve the Services’ performance. Some cookies are necessary in order to use the Services, and these cannot be disabled. Other cookies are not required to browse our Services and may be disabled or deleted, but this may prevent you from properly using the Services. Most browsers allow you to adjust your cookie settings, which can be done through your browser’s settings. Third-party services, such as Shopify, may employ cookies on the Services in order to better perform their services. We have no control over third-party cookies, and therefore, disclaim any and all liability related to third-party cookies.
17. Canadian Residents. If you are located in Canada, this section applies to you. We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time by emailing us at hello@theverticale.com. In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example: (i) if collection is clearly in the interests of an individual and consent cannot be obtained in a timely way; (ii) investigations and fraud detection and prevention; (iii) business transactions provided certain conditions are met, and (iv) other reasons as may be allowed under applicable law.
18. Supplemental Privacy Rights. If you are a California, Colorado, Connecticut, Nevada, Utah or Vermont resident, the law may provide you with additional rights regarding our use of your Personal Information. Please review our Supplemental Privacy Policy[DF1] carefully to learn more about these rights.
19. Appealing Privacy Rights Decisions. Depending on your U.S. state residency, you may have the right to appeal a decision we have made in connection with your privacy rights request. To appeal a decision, please contact Hello@theverticale.com. If you are unsatisfied with the way that we have handled your appeal, you may have the right to complain to your state’s Attorney General.
20. Changes and Updates to Privacy Policy. This Privacy Policy may be revised periodically, and this will be reflected by the date above. Please revisit this page to stay aware of any changes. Your continued use of the Services constitutes your agreement to this Privacy Policy and any future revisions.
21. Contact Information. If you have any questions or concerns about this Privacy Policy, please contact us by email at the following address: Hello@theverticale.com.
U.S. Supplemental Privacy Policy
Updated as of: April 30, 2023
This US Supplemental Privacy Notice (“Supplemental Notice”) applies only to information collected about consumers in the following states: (1) California, (2) Colorado, (3) Connecticut, (4) Nevada, (5) Utah, and (6) Virginia. This Supplemental Notice describes The Verticale, LLC’s (“we,” “us,” “our”) practices regarding the collection, use, and disclosure of Personal Information and provides instructions for submitting data subject requests. This Supplemental Notice is in addition to, and incorporated into, our Privacy Policy.
Some portions of this Supplemental Notice apply only to consumers of particular states. In those instances, we have indicated that such language
applies only to those consumers.
To the extent terms used in this Supplemental Notice are defined terms under the applicable US State Privacy Law, they shall have the meanings afforded to them in those statutes, whether or not capitalized herein. As there are some variations between such definitions in each of the state statutes, the definitions applicable to you are those provided in the statute for the state in which you are a consumer. For example, if you are a Virginia consumer, terms used in this Supplemental Notice that are defined terms in the VCDPA shall have the meanings afforded to them in the VCDPA as this Supplemental Notice applies to you.
Supplemental Notice for California Residents. This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information The Verticale has collected about them, and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months.
Disclosure for California Consumers: Unless specifically stated, we have not sold or shared Personal Information about California consumers to third parties for their own use in the past twelve months. Relatedly, we do not have actual knowledge that we sell or share Personal Information of California consumers under 16 years of age. However, we may share your personal information with our affiliates and trusted partners in arrangements that may meet the broad definition of “sale” or “share” under California law. In these arrangements, use of the information we share is limited by policies, contracts, or similar restrictions. That said, we may share information with third-party advertising partners or analytics providers for the purpose of promoting our Services as described above, including for cross-context behavioral advertising. To the extent that such sharing is considered a “sale” under the CCPA, you may opt-out of having your personal information shared with such advertising partners or analytics providers by emailing us here: Hello@theverticale.com. For purposes of California law, a “sale” is the disclosure of Personal Information to a Third Party for monetary or other valuable consideration, and a “share” is the disclosure of Personal Information to a Third Party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.
Additional Privacy Rights for California Residents:
Right to Access. If you are a California consumer, you have the right to ask us to send you the following information up to two times in a twelve-month period: (i) categories of personal data we have collected about you; (ii) categories of sources from which we collected the personal data; (iii) our business or commercial purpose for collecting personal data; (iv) categories of third parties with whom we share personal data; (v) categories of personal data we disclose about you for business purposes; (vi) categories of personal data we sell or exchange for consideration about you; and (vii)
the specific pieces of personal information we have collected about you.
Right to Delete. If you are a California consumer, you have the right to ask us to delete the personal data about you we have collected. We may deny the request if the information is necessary to: (i) complete a transaction, including providing a requested or reasonably anticipated good or service, or fulfill a contract between the consumer and The Verticale; (ii) detect and protect against security incidents, malicious, deceptive, fraudulent, or illegal activity, or take against those responsible for such activity; (iii) debug to identify and repair errors impairing intended functionality; (iv) comply with the California Electronic Communications Privacy Act; (v) engage in research in the public interest adhering to applicable ethics and privacy laws where the consumer has provided informed consent; (vi) enable solely internal uses reasonably aligned with the consumer’s expectations based on the consumer’s relationship with The Verticale; (vii) comply with a legal obligation; or (viii) otherwise use the information internally in a lawful manner compatible with the context in which the consumer provided the information.
Right to portability. A consumer has the right to request personal information about the consumer be disclosed in a common file format.
Right to Opt-out of the sale of Personal Information. If a business sells personal information to third parties, California consumers have the right, at any time, to opt out of the sale or disclosure of their personal information to third parties. The Verticale does not sell personal information to third parties, except in conjunction with a corporate sale, merger, dissolution, or acquisition.
Right to designate an authorized agent. You have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, please contact us.
Right to non-discrimination. The CCPA grants California consumers the right not to be discriminated against for exercising your privacy rights. If you exercise your privacy rights, we will not discriminate against you, for example, by denying you access to our shop or charging you different rates or prices for the same The Verticale Services, unless that difference is reasonably related to the value provided by your data.
California Privacy Rights Act. In addition to the rights provided by the CCPA, California residents are provided with the following rights through the California Privacy Rights Act: (i) the right to request that incorrect or outdated personal information be corrected but not deleted; (ii) the right to restrict a business’s ability to process sensitive data about the consumer; and (iii) prohibition against a business making decisions about a consumer based solely on an automated process without human input.
California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.
Disclosure About Direct Marketing for California Residents. California Civil Code § 1798.83 permits California residents to annually request certain information regarding our disclosure of Personal Information to other entities for their direct marketing purposes in the preceding calendar year. We do not distribute your Personal Information to other entities for their own direct marketing purposes.
Supplemental Notice for Colorado Residents. The Colorado Privacy Act provides Colorado residents with the following rights: (i)the right to opt out of the processing of personal data concerning the consumer; (ii) the right to confirm whether a business is processing personal data concerning the consumer and to access the consumer’s personal data; (iii) the right to correct inaccurate personal data collected from the consumer; (iv) the right to delete personal data concerning the consumer; (v) the right to restrict a business’s ability to process personal information about the consumer, specifically to opt-out of processing for profiling/targeted advertising purposes; (vi) a prohibition against a business making certain decisions about a consumer based solely on an automated process without human input; and (vii) the right to data portability. When exercising the right to access personal data, a consumer has the right to obtain the personal data in a portable, and to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another entity without hinderance. A consumer may exercise this right no more than two times per calendar year.
Supplemental Notice for Connecticut Residents. The Connecticut Data Privacy Act provides Connecticut residents with the following rights: (i) the right to confirm whether a business is processing personal data concerning the consumer and to access the consumer’s personal data; (ii) the right to request that incorrect or outdated personal information be corrected but not deleted; (iii) the right to delete personal data concerning the consumer; (iv) the right to restrict a business’s ability to process sensitive data about the consumer- specifically to opt-out of processing for profiling/ targeted advertising purposes; (v) the right to request personal information about the consumer be disclosed in a common file format; (vi) the right to opt out of the sale of personal information about the consumer to third parties; and (vii) prohibition against a business making certain decisions about a consumer based solely on an automated process without human input.
Supplemental Notice for Nevada Residents. We generally do not disclose or share personal information for profit. If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. To exercise this right, if applicable, you or your authorized representative may submit a request to [INSERT EMAIL]. If you have any questions, please contact us at [INSERT EMAIL]. We will respond to your verified request as soon as reasonably practicable, but no later than sixty (60) days after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response.
Supplemental Notice for Utah Residents. The Utah Consumer Privacy Act provides Utah residents with the following rights: (i) the right to confirm whether a business is processing personal data concerning the consumer and to access the consumer’s personal data; (ii) the right to delete personal data concerning the consumer; (iii) the right to restrict a business’s ability to process sensitive data about the consumer- specifically to opt-out of processing for profiling/ targeted advertising purposes; (iv) the right to request personal information about the consumer be disclosed in a common file format; and (v) the right to request to opt out of the sale of personal information about the consumer to third parties.
Supplemental Notice for Virginia Residents. The Consumer Data Protection Act provides Virginia residents with the following rights: (i) the right to confirm whether or not a controller is processing the consumer’s personal data and to access such personal data; (ii) the right to delete personal data provided by or obtained about the consumer; (iii) the right to obtain a copy of the consumer’s personal data that the consumer previously provided to the business in a portable and, to the extent technically feasible, readily usable format; iv) the right to opt out of the processing of the personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer; and (vi) the right to restrict a business’s ability to process personal information about the consumer, specifically to opt-out of processing for profiling/targeted advertising purposes.
Disclosure for Colorado, Virginia, Utah, and Connecticut Consumers: Unless specifically stated, we do not sell or share Personal Information to Third Parties for their own use. However, we may share or process one or more of the above categories of personal information with our affiliates and trusted partners in arrangements for purposes of targeted advertising, as the terms “sell,” “share,” “process,” and “targeted advertising” are defined in the CPA, VCDPA, UCPA, and CTDPA. In these arrangements, use of the information we share is limited by policies, contracts or similar restrictions.
Changes to this Supplemental Notice: We reserve the right to amend this Supplemental Notice at our discretion and at any time. When we make material changes to this Supplemental Notice, we will notify you by posting an updated Supplemental Notice on our website and listing the effective date of such updates.
Contact Us: For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e‑mail at hello@theverticale.com or by mail using the details provided below:
THE VERTICALE INC.
3435 Ocean Park Blvd #107
Santa Monica, CA 90405