VittaGems (“VittaGems,” “we,” “us,” or “our”) is committed to protecting your privacy.We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect, use, and share in connection with the VittaGems website, mobile app, and other software provided on or in connection with our services, as described in our Terms of Service (collectively, the “Service”). “VGMG” or “Token” in this Privacy Policy means a utility stablecoin or similar digital asset implemented on a blockchain, which uses smart contracts to link to or otherwise be associated with certain verified physical precious assets including gold and diamonds.
1. Types of Data We Collect
“Personal Data” means data that allows someone to identify you individually, including, for example, your name, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing. “Anonymous Data” means data, including aggregated and de-identified data, that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data as described below.
1.1 Information You Provide Us
When you use our Service, update your account profile, or contact us, we may collect Personal Data from you, such as email address, first and last name, user name, and other information you provide. We also collect your blockchain address, which may become associated with Personal Data when you use our Service. Our Service lets you store preferences like how your content is displayed, notification settings, and favorites. We may associate these choices with your ID, browser, or mobile device. If you provide us with feedback or contact us, we will collect your name and contact information, as well as any other content included in the message. We may also collect Personal Data at other points in our Service where you voluntarily provide it or where we state that Personal Data is being collected.
1.2 Information Collected via Technology
As you navigate through and interact with our Service, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including Information Collected by Our Servers. To provide our Service and make it more useful to you, we (or a third-party service provider) collect information from you, including, but not limited to, your browser type, operating system, Internet Protocol (“IP”) address, mobile device ID, blockchain address, wallet type, and date/time stamps.
Log Files. As is true of most websites and applications, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamps, and clickstream data. We use this information to analyze trends, administer the Service, track users’ movements around the Service, and better tailor our Services to our users’ needs.
Cookies. Like many online services, we use cookies to collect information. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to analyze how users interact with our Service, make improvements to our product quality, and provide users with a more personalized experience.
Pixel Tags. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags allow us to analyze how users find our Service, make the Service more useful to you, and tailor your experience with us to meet your particular interests and needs.
How We Respond to Do Not Track Signals. Our systems do not currently recognize “do not track” signals or other mechanisms that might enable users to opt-out of tracking on our site.
Analytics Services. In addition to the tracking technologies we place like Cookies and Pixel Tags, other companies may set their own cookies or similar tools when you visit our Service. This includes third-party analytics services (“Analytics Services”) that we engage to help analyze how users use the Service. The information generated by the Cookies or other technologies about your use of our Service (the “Analytics Information”) is transmitted to the Analytics Services. Analytics Services use Analytics Information to compile reports on user activity, which we receive on an individual or aggregate basis. We use the information we get from Analytics Services to improve our Service. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ terms of use and privacy policy. By using our Service, you consent to the processing of data about you by analytics services in the manner and for the purposes set out above.
1.3 Information Collected from Third-Party Companies
We may receive Personal and/or anonymous data about you from companies that offer their products and/or services for use in conjunction with our service or whose products and/or services may be linked to our Service. For example, third-party wallet providers provide us with your blockchain address and certain other information you choose to share with those wallet providers. We may add this to the data we have already collected from or about you through our Service. Furthermore, as part of our Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance, we may receive information from identity verification services.
1.4 Public Information Observed from Blockchains
We collect data from activity that is publicly visible and/or accessible on blockchains. This may include blockchain addresses and information regarding purchases, sales, or transfers of VGMG tokens or other digital assets, which may then be associated with other data you have provided us.
2. Use of Your Personal Data
- We process your Personal Data to run our business, provide the Service, personalize your experience with the Service, and improve the Service. Specifically, we use your Personal Data to facilitate the creation of and secure your account, and to identify you as a user in our system. We also use your data to provide you with our Service, including, but not limited to, helping you view, explore, and manage VGMG tokens and, at your own discretion, connect directly with others to purchase, sell, or transfer tokens on public blockchains. Furthermore, we utilize this information to improve the administration of our Service and the quality of your experience when you interact with our platform.
- Your Personal Data is essential for us to provide customer support and respond to your requests and inquiries. We rely on this data to investigate and address conduct that may violate our Terms of Service, as well as to detect, prevent, and address fraud, violations of our terms or policies, and other harmful or unlawful activities. Importantly, we process your information to comply with applicable laws, including FinCEN regulations, AML/CFT requirements, and sanctions compliance programs. We will cooperate with investigations by law enforcement or other authorities regarding suspected violations of law, and we may use your data to pursue or defend against legal threats and claims.
- In terms of communication, we use your Personal Data to send you a welcome email to verify ownership of the email address provided when your account was created. We will also send you administrative notifications, such as security, support, and maintenance advisories. Additionally, we may send you notifications related to actions on the service, including updates regarding your loyalty program tier and redemption options. We may send you newsletters, promotional materials, and other notices related to our Services, and we will respond to your inquiries related to employment opportunities or other requests. Finally, we may act in any other way we describe when you provide the Personal Data.
- We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Service navigation. We reserve the right to use Anonymous Data for any purpose and to disclose Anonymous Data to third parties without restriction.
3. Disclosure of Your Personal Data
We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.
3.1 Third Party Service Providers
We may share your Personal Data with third party service providers to provide you with the Services that we offer you through our Service, conduct quality assurance testing, facilitate the creation of accounts, provide technical support, verify your identity for AML/KYC purposes, and to provide other services to VittaGems.
3.2 Affiliates
We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.
3.3 Corporate Restructuring
We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition, or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
3.4 Legal Rights
Regardless of any choices you make regarding your Personal Data (as described below), VittaGems may disclose Personal Data if it believes in good faith that such disclosure is necessary in connection with any legal investigation, to comply with relevant laws or to respond to subpoenas, warrants, or other legal process served on VittaGems, to protect or defend the rights or property of VittaGems or users of the Service, and to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Service.
3.5 Other Disclosures
We may also disclose your Personal Data to fulfill the purpose for which you provide it, for any other purpose disclosed by us when you provide the information, or with your consent.
4. Third-Party Websites
Our Service may contain links to third-party websites. When you click on a link to any other website or location, you will leave our Service and go to another site, and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.
5. Third-Party Wallets
To use our Service, you must use a third-party wallet which allows you to engage in transactions on public blockchains. Your interactions with any third-party wallet provider are governed by the applicable terms of service and privacy policy of that third party.
6. Your Choices Regarding Information
You have several choices regarding the use of information on our Services.
6.1 Email Communications
We may periodically send you free newsletters and e-mails that directly promote the use of our Service or third parties’ goods and services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by updating your preferences in your account. Despite your indicated e-mail preferences, we may send you occasional service-related communications, including notices of updates to our Terms of Service or Privacy Policy.
6.2 Cookies
If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service.
7. Data Access and Control
- You can view, access, edit, or delete your Personal Data for certain aspects of the Service via your Settings page. You may also have certain additional rights depending on your jurisdiction.
- If you are a user in the European Economic Area or United Kingdom, you have certain rights under the respective General Data Protection Regulation (“GDPR”). These include the right to request access and obtain a copy of your Personal Data, request rectification or erasure of your Personal Data, object to or restrict the processing of your Personal Data, and request portability of your Personal Data. Additionally, if we have collected and processed your Personal Data with your consent, you have the right to withdraw your consent at any time.
- If you are a California resident, you have certain rights under the California Consumer Privacy Act (“CCPA”). These include the right to request access to, details regarding, and a copy of the Personal Data we have collected about you and shared with third parties, request deletion of the Personal Data that we have collected about you, and the right to opt-out of the sale of your Personal Data. As the terms are defined under the CCPA, we do not “sell” your “Personal Data.”
- If you wish to exercise your rights under the GDPR, CCPA, or other applicable data protection or privacy laws, please contact us at the address provided in Section 13 below. Please specify your request and reference the applicable law. We may ask you to verify your identity, or ask for more information about your request. We will consider and act upon any above request in accordance with applicable law. We will not discriminate against you for exercising any of these rights.
- Notwithstanding the above, we cannot edit or delete any information that is stored on a blockchain, as we do not have custody or control over any blockchains. The information stored on the blockchain may include purchases, sales, and transfers related to your blockchain address and tokens held at that address.
8. Data Retention
We may retain your Personal Data as long as you continue to use the Service, have an account with us, or for as long as is necessary to fulfill the purposes outlined in this Privacy Policy. We may continue to retain your Personal Data even after you deactivate your account and/or cease to use the Service if such retention is reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our Terms or other agreements, and/or protect our legitimate interests. Where your Personal Data is no longer required for these purposes, we will delete it.
9. Security
We care about the security of your information and use physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through our Service. However, no security system is impenetrable and we cannot guarantee the security of our systems. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
You are responsible for the security of your digital wallet, and we urge you to take steps to ensure it is and remains secure. If you discover an issue related to your wallet, please contact your wallet provider.
10. Minors
We do not intentionally gather Personal Data from visitors who are under the age of 13. Our Terms of Service require all users to be at least 18 years old. Minors who are at least 13 years old but are under 18 years old may use a parent or guardian’s VittaGems account, but only with the involvement of the account holder. If a child under 13 submits Personal Data to VittaGems and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at the address provided in Section 13 below.
11. Users Outside of the United States
If you are a non-U.S. user of the Service, by visiting the Service and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your Personal Data, you consent to such transfer.
12. Changes to This Privacy Policy
This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy at https://vittagems.com/privacy-policy. The date the Privacy Policy was last revised is identified at the beginning of this Privacy Policy. You are responsible for periodically visiting our Service and this Privacy Policy to check for any changes.
13. Questions; Contacting VittaGems; Reporting Violations
If you have any questions, concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at:
VittaGems
Email: jeff@cgiagent.com
Website: https://vittagems.com/