Last Updated: April 15, 2018
For All Non-US Residents
For European Union Residents
For purposes of enforcing compliance with the Privacy Shield, Vinli is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission.
You Will Not be Spammed by Vinli
We may periodically send you email communications inviting you to participate in surveys, as well as occasional newsletters, fulfillment communications, Developer Portal announcements and promotional emails. If you no longer want to receive these email communications, you must request that Vinli discontinue sending you email by clicking on the “Unsubscribe” link at the bottom of the email, or by cancelling your Developer Portal membership as described in “Our Opt-Out Policy” section below.
Information We Collect
Vinli collects, uses and shares information about our customers and the users of Vinli Services, including our customers and users in the European Union. To purchase products or use certain Vinli Services, you are required to give us certain contact information and personal data (e.g., your full name, physical address, email address, etc.). If you fail to provide certain information, you will be unable to purchase or use certain features of our products or access the full functionality of the Vinli Services.
- Vinli collects and provides personally identifiable information and other related data, including vehicle-associated data (e.g., VIN, vehicle performance, driving behavior and location data) collected by Vinli), to our agents and third party partners (the “Telematics Data”).
- Vinli may also collect data from certain 3rd party partners to correlate that data with European Union and non-European Union customers’ and users’ Telematics Data where applicable.
- When you use Vinli Services, Vinli collects and processes information about your actual physical location. The Vinli Services collect location data through various means, including GPS, IP address, and information received from cell phone towers, Wi-Fi access points and other sensors.
- Vinli also uses various technologies, including cookies, to tell us and our partners more about the kinds of browsers and devices you are using to access and enjoy Vinli Services. The Vinli Services may also collect other personal information about you, including your vehicle’s VIN.
How We Use and Share the Information We Collect
Vinli uses the information it collects through the Vinli Services (including personal and location information) for several purposes, including, without limitation:
- processing orders and other transactions made through the Vinli Services;
- augmenting user information with statistical information available from a third party;
- sharing, licensing and selling this information to third parties for business, marketing and research purposes, including, but not limited to, personalizing and enhancing your Vinli experience, allowing Vinli and its third party partners to deliver content to you, providing other products and services to you, and researching user and vehicle behavior;
- sharing, licensing and selling this information with third-party application developers and application providers in accordance with the “Third-Party Applications” section below;
- combining this information with information from other Vinli users to create aggregate data, which may be shared, licensed or sold to third parties for business and marketing purposes; and
- contacting you about our products and services and providing direct offers or promotions to you.
For example, Vinli may collect, share, license and sell certain information related to your geographic location or other information to third-party advertisers with the ability to target their ads to you or other commercial information to further enhance your Vinli experience.
In addition, we reserve the right to disclose your information, including personally identifiable information and location data as required by law or when we believe that disclosure is necessary to protect our rights or comply with a judicial proceeding, court order, or legal process served on Vinli.
If Vinli goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, you agree that your personally identifiable information may be transferred to such entities. In such cases, we may publish certain details about such event on our websites. Unless you expressly request us delete your personally identifiable information by contacting us by any means provided in the “How to Contact Us” section below, Vinli may use and retain the information collected through the Vinli Services for as long as necessary to serve the business purposes of Vinli in compliance with this policy.
Sharing With Third-Party Application Developers and Providers
Under certain circumstances, Vinli may remain liable for the acts of Third Parties who perform services on our behalf for their handling of Personal Data that we transfer to them.
Please be aware that Vinli may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
The Vinli Services may contain links to other internet sites that are not operated or controlled by Vinli. We cannot control and are not responsible for the privacy practices or the content of such websites.
California Shine the Light Law
California Civil Code Section 1798.83 permits you to request and obtain from us once a year, free of charge, a list of the third parties to whom we disclosed your personal information as defined under that statute, for direct marketing purposes in the preceding calendar year and the categories of that kind of personal information that was disclosed to them. If you are a California resident and you wish to make such a request you may by contacting us by any means provided in the “How to Contact Us” section below.
How to Edit or Correct Your Personal Information
To change or delete your personally identifiable information from the Vinli database, please contact us by any means provided in the “How to Contact Us” section below. We will make commercially reasonable efforts to respond to your request within 30 days of its submission.
If you wish to terminate your account or request that we no longer use your personal information, contact us by any means provided in the “How to Contact Us” section below. If you terminate your account or ask that we no longer use your personal information, we will use reasonable efforts to instruct our third party partners with whom we have shared your information of your request.
EU individuals have the right to access EU Personal Data about them and to limit use and disclosure of their EU Personal Data. Vinli has committed to respect those rights in accordance with Privacy Shield. If you wish to request access, limit use or limit disclosure, please contact us by any means provided in the “How to Contact Us” section below.
Vinli acknowledges that EU individuals have the right to access the personal information that we maintain about them. An EU individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to the “How to Contact Us” section below. If requested to remove data, we will respond within a reasonable timeframe.
Commitment to Data Security
The Vinli Services have certain commercially reasonable security measures in place to help protect against the loss, misuse, and alteration of the information submitted through them. However, and as with any transmission over the internet, there is always some element of risk involved in sending personal information online. Remember to keep your passwords private and secure — you should not share this information with anyone. If you have any questions about the security of the Vinli Services, please contact us through any means as stated in the “How to Contact Us” section below.
Commitment to Children’s Privacy
- Vinli Does Not Seek To Collect From Children Under 13 Years Of Age
Vinli takes children’s privacy seriously and we do not seek to collect individually identifiable information about children under 13 years of age. If Vinli learns that a child under the age of 13 has submitted personally identifiable information through the websites, products or the Developer Portal, in contravention of these measures, Vinli will take all reasonable measures to delete such information from its databases and to not use such information for any purpose.
- California Minors
If you are a California resident who is under 18 and a user of our websites, products or Developer Portal, this section applies to you. We may provide users the functionality of posting information through our websites, products or Developer Portal. If and to the extent CA Bus. & Prof. § 22581 applies, you may request and obtain removal of content or information posted by you (as an account holder) subject to the exceptions provided in this “California Minors” section. If you can accomplish removal on your own by following the instructions within the websites, products or Developer Portal, then follow those instructions. If that does not work, contact us by using the contact information provided in the “How to Contact Us” section below by specifying the information or content and each place where it is located in enough detail so that we reasonably can find it and meet your request in the ordinary course of our business. CA Bus. & Prof. § 22581 provides exceptions to your ability to request and obtain removal of content or information posted by you within the websites, products or Developer Portal. Those exceptions in CA Bus. & Prof. § 22581 are: (1) federal or state laws requiring us or a third party to maintain the content or information; (2) the content or information is not covered by the law (e.g., someone other than you posted it or your posting is stored, republished, or reposted by a third party); (3) we turned your content or information into anonymized data (such as, aggregated data or the like) and thereby disabling the ability to identify your content and information among other users’ content or information; (4) you don’t follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the content or information. If any one of the above exceptions applies, we are not required to remove your content or information from the Aps. REMOVAL OF YOUR POSTED CONTENT OR INFORMATION FROM THE WEBSITES AND DEVELOPER PORTAL DO NOT ENSURE COMPLETE OR COMPREHENSIVE REMOVAL OF THAT CONTENT OR INFORMATION. The law does not require us to actually eliminate the information posted by you; the law is satisfied if we keep it but render it invisible to other users and the public. Also, some information will already be beyond our control (e.g., a user or other third party might have already copied it). Law enforcement may obtain the content or information pursuant to certain court orders.
Cookies and Do Not Track
Our Opt-Out Policy
If you would like to terminate any of your Vinli Service accounts, you may request that we close your account(s) by contacting us by any means provided in the “How to Contact Us” section below. The use of any other mechanism to request that your membership be cancelled could result in the delay of your membership cancellation.
Vinli has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
How to Contact Us
If you have any questions about this privacy statement or your interaction with the Vinli Services, you can contact us by email at firstname.lastname@example.org or by mail at 2203 Commerce St., Dallas, Texas 75201, United States of America.