Online Privacy Policy

Updated as of December 20, 2016

The VinaCircle privacy policy describes how VinaCircle and its subsidiaries treat personal information when you use VinaCircle's services, including information provided when you register or use VinaCircle's features.

INTRODUCTION AND GENERAL TERMS

VinaCircle ("VinaCircle") recognizes that its customers, visitors, Members, and others who use www.VinaCircle (the "VinaCircle Site") (collectively or individually "Members") value their privacy. This Privacy Notice details important information regarding the use and disclosure of User information collected on the VinaCircle Site. VinaCircle provides this Privacy Notice to help you make an informed decision about whether to use or continue using the VinaCircle Site. This Privacy Notice is incorporated into and is subject to the VinaCircle Terms of Use. Your use of the VinaCircle Site and any personal information you provide on the VinaCircle Site remains subject to the terms of this Privacy Notice and our Terms of Use.

By visiting the VinaCircle Site (whether or not you are a registered member) or using any of the VinaCircle Services on any of the Sites, you are accepting this Privacy Policy. If you do not want information about you to be used in the manner set forth in this Privacy Policy, please do not use the VinaCircle Services.

THE INFORMATION VinaCircle COLLECTS

Account Information

When you register, we may ask for information such as your name, email address, birth date and gender. From time to time, we may also ask you optionally to provide other information. If you choose to provide such information, you are giving VinaCircle the permission to use and store it consistent with this policy. Therefore, please understand when you sign in to the VinaCircle site, you are not anonymous to us.

Account Information is used:

  • to personalize communications to you and identify you in our system.
  • for identity verification
  • emailing of system messages, personal VinaCircle messages, VinaCircle newsletters, special offers and other VinaCircle communications.
  • to determine whether you are of legal age to view mature content.

 

Profile

Your supplied gender, age and chosen username will be displayed as part of your public profile, you may however, also elect to provide more information about yourself in your profile. VinaCircle does not require you to fill out the extra fields on your profile in order to participate in the service or community. VinaCircle makes no claims about the privacy of publicly available profile information.

Cookies, log files and clear GIF information

When you visit the VinaCircle Site, we may send one or more cookies - a small text file containing a string of alphanumeric characters - to your computer that uniquely identifies your browser. VinaCircle uses both session cookies and persistent cookies. A persistent cookie remains after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser help file directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the VinaCircle Site may not function properly if the ability to accept cookies is disabled. We do not link the information we store in cookies to any personally identifiable information you submit while on our site.

When you use the VinaCircle Site, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol ("IP") address, browser type, browser language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, and one or more cookies that may uniquely identify your browser.

When you use the VinaCircle Site, we may employ "clear GIFs" (a.k.a. Web Beacons) which are used to track the online usage patterns of our Members anonymously (i.e., in a non-personally-identifiable manner). In addition, we may also use clear GIFs in HTML-based emails sent to our Members to track which emails are opened by recipients.

The cookies, log files and clear GIF information is used to:

  • remember information so that you will not have to re-enter it during your visit or the next time you visit the VinaCircle Site;
  • provide custom, personalized content and information;
  • monitor the effectiveness of our marketing campaigns;
  • monitor aggregate metrics such as total number of visitors, pages viewed, etc.;
  • track your entries, submissions, and status in promotions and contests;
  • determine where you are accessing the VinaCircle site from geographically and which services are therefore available.

Surveys and polls

VinaCircle values opinions and comments from members, so we may conduct online surveys. Participation in these surveys is entirely optional. Typically, the information is aggregated and used to make improvements to VinaCircle and to develop appealing content, features and promotions for members. Survey participants are anonymous unless otherwise stated in the survey.

Forums, comments and private messaging

Any personally identifiable information you submit through the forums and comments system can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these forums or by private message to other users.

Combined information

We use both your personally identifiable information and certain non-personally-identifiable information (such as anonymous User usage data, cookies, IP addresses, browser type, clickstream data, etc.) to improve the quality and design of the VinaCircle Site and to create new features, promotions, functionality, and services by storing, tracking, and analyzing User preferences and trends.

Anonymous aggregated data

Anonymous data is information (originally personally identifiable or non-personally identifiable) that subsequently is used in aggregate form. We may use anonymous data for purposes of research or analysis. We may conduct research on our customer demographics, internet usage, and interests and behavior based on personal data we gather. Although anonymous data may be based in part on personal data, it does not identify you personally.

Film viewing history

VinaCircle stores information about which films you watch in streaming flash format. The list of films is also posted to your public profile.

This information is used to:

  • improve the site experience.
  • allow friends to recommend movies to each other.
  • track film watches so we can return royalties to the film distributors.

 

WHEN VINACIRCLE DISCLOSES INFORMATION

Site functionality and marketing

We do share non-personally-identifiable information (such as anonymous User usage data, referring / exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to assist them in understanding the usage patterns for certain content, services, advertisements, promotions, and/or functionality on the VinaCircle Site.

We may use your personally identifiable information to provide you with information about VinaCircle's features, services, and other offerings that may be of interest to you; send information or offers to users on behalf of VinaCircle's partners (please note that if we were to do this, we would not give those partners personally identifiable information such as your name or address); or share your personally identifiable information with advertisers, business partners, and other entities that are not affiliated with VinaCircle who would like to send you information about their products and services.

Contests

If you win a contest, we may post limited personally identifiable information on the VinaCircle Site. However, we will notify you of this possibility when collecting personally identifiable information or we will obtain your consent.

VinaCircle suppliers

We may share your personally identifiable information with companies that provide services to us, including outside contractors or agents who help us manage our information activities (for example, contest and sweepstakes administration). But they may only use your personally identifiable information to provide us with a specific service and not for any other purpose. Similarly, we may share your personally identifiable information with other people or entities in order to provide goods or services that you have requested or to complete a transaction at your request.

Legal requirements and VinaCircle protection

There may be instances when we may disclose personally identifiable information without providing you with a choice in order to protect the legal rights of VinaCircle or its affiliates, and each of their respective investors, directors, officers, employees, agents, and suppliers; to protect the safety and security of users of the VinaCircle Services or to enforce our Terms of Use; to protect against fraud or for risk management purposes; or to comply with or respond to the law or legal process, whether or not legally required. If you submit a Notice of Copyright Infringement pursuant to the Terms of Use, we will send a copy to the person or entity who uploaded, stored, or transmitted the material addressed by the communication.

YOUR CHOICES

Decline

You may, of course, decline to submit personally identifiable information through the VinaCircle Site, in which case VinaCircle may not be able to provide certain services to you.

Responsibility

To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.

Contact Us

If you have concerns regarding this Privacy Policy, including if you believe that VinaCircle may have incorrect information for you or if you would like your personally identifiable information to be permanently removed from our database, you may email us at privacy@VinaCircle.com

Emails sent to privacy@VinaCircle.com for purposes other than communication about personally identifiable information may not be answered.

THIRD-PARTY COMPANIES

If you choose to use our referral service to tell a friend about our site we will ask you for your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site. VinaCircle stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program.

Your friend may contact us privacy@VinaCircle.com to request that we remove this information from our database.

The VinaCircle Services may be linked to websites operated by other companies. Some of these websites may be co-branded with our name or logo, even though they are not operated or maintained by us. VinaCircle is not responsible for the privacy practices of other websites operated by third parties that are linked to any of the Sites. Once you have left the VinaCircle Site by clicking on a link, you should check the privacy policy of the other website to determine how it handles any personally identifiable information they collect from you.

VinaCircle carries advertisements from other companies, often with the ability to click through to websites run by such other companies. VinaCircle is not responsible for the privacy practices of advertisers. Once you have left the VinaCircle Site by clicking on an advertisement, you should check the privacy policy of the advertiser to determine how it handles any personally identifiable information they collect from you. Please be aware that VinaCircle does not warn you when you have chosen to link through to another website from the VinaCircle Site.

Some of the advertisements that appear in connection with the VinaCircle Services may be delivered to you by internet advertising companies (also called "ad networks" or "network advertisers"). These companies may use cookies and other technologies to deliver advertisements to you, measure their effectiveness, and personalize advertising content. VinaCircle does not have access to or control over cookies or other technologies that they may use. The information practices of these advertising companies are governed by their own privacy policies and are not covered by this Privacy Policy.

Please note that if you are accessing VinaCircle from outside the UK and you make a comment or complaint regarding any element of advertising (see paragraph 11 for more details about this) then VinaCircle may forward your correspondence to VinaCircle only for the purposes of responding to you.

We use third-party advertising companies to serve ads when you visit our Web site. These companies may use aggregated information (not including your name, address, email address or telephone number) about your visits to this and other Web sites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here http://www.networkadvertising.org/managing/opt_out.asp

DATA SECURITY

Safeguards

VinaCircle uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you transmit to VinaCircle and you do so at your own risk. Once we receive your transmission of information, VinaCircle makes commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

Notification

If VinaCircle learns of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. VinaCircle may post a notice on the VinaCircle Site if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach you should notify us at privacy@VinaCircle.com

 

Children

VinaCircle does not knowingly collect or maintain personally identifiable information or non-personally-identifiable information on the VinaCircle Site from persons under 13 years of age, and no part of our website is directed to persons under 13. If you are under 13 years of age, then please do not use or access the VinaCircle Site at any time or in any manner unless under the supervision of a parent or guardian . If VinaCircle learns that personally identifiable information of persons less than 13 years of age has been collected on the VinaCircle Site without verified parental consent, then VinaCircle will take the appropriate steps to delete this information.

INTERNATIONAL MEMBERS

If you are a user accessing the VinaCircle Site from a region outside Barbados, with laws or regulations governing personal data collection, use, and disclosure, that differ from Barbados laws, please be advised that through your continued use of the VinaCircle Site, which are governed by Barbados law, this Privacy Notice, and our Terms of Use, you are transferring your personal information to Barbados and you consent to that transfer.

BUSINESS TRANSACTIONS

In the event VinaCircle goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personally identifiable information will likely be among the assets transferred. You will be notified via email or prominent notice on our Web site for 30 days of any such change in ownership or control of your personal information.

HOW LONG WILL VINACIRCLE KEEP MY PERSONAL INFORMATION?

We will hold your personal information on our systems for as long as is necessary for the relevant service, or as long as is set out in any relevant contract you hold with VinaCircle.

Where you contribute to VinaCircle will generally only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted.

CHANGES TO VINACIRCLE'S PRIVACY POLICY

From time to time, VinaCircle may revise this Privacy Policy to reflect industry initiatives or changes in the law or to the scope of the VinaCircle Services, among other reasons. Any revisions will be effective upon posting the new Privacy Policy onto our VinaCircle APP. Therefore, it is important to check the Privacy Policy posted at this location each time you visit the VinaCircle Site or use any of the VinaCircle Services to ensure you are familiar with the most updated policies and practices. If you do not agree with any changes to the Privacy Policy, you must leave the VinaCircle Site and discontinue any use of the VinaCircle Services. Any visit to the VinaCircle Site or use of the VinaCircle Services on any of the Sites by you after the new Privacy Policy is posted will indicate your agreement to the new Policy.

 

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