Introduction
Vine Advisors (also referred to below as “we”, “us” and “our”) is a privacy conscious organization. This Privacy Policy explains how we protect your information collected from (1) the Web pages of thevineadvisors.com website that are designated in the upper left hand corner or Web pages of any other website with respect to which this Privacy Policy is posted or linked (such Web pages are collectively referred to as the “Website”), (2) downloadable applications accessed from mobile devices with respect to which this Privacy Policy is posted or linked (“Mobile Apps”) or (3) any other mode of interacting with you relating to Vine Advisors communications, such as online or offline newsletters and magazines, that reference this Privacy Policy (“Communication”). By using the Website or Mobile Apps, or continuing to receive Communications, you agree to the use of such information in accordance with this Privacy Policy. This Privacy Policy also applies to your personal information that we may have collected from data brokers in connection with our marketing activities.
The thevineadvisors.com website also includes Web pages provided for PWR LLC https://thevineadvisors.com/pwr/ which are designated according to the location identified in the upper left-hand corner next to “Location.” These Web pages are provided by the Vine Advisors and are the responsibility of Vine Advisors. Such Web pages are governed by this Privacy Policy.
Information collection
We may collect personal information when you interact with the Website or Mobile Apps, such as if you choose to receive complimentary consultations or a Mobile App (e.g., to gain access to specific content, or request Communications about specific areas of interest), or otherwise provide it to us. Depending on the specific Communication you are receiving, or the Web page of the Website or Mobile App you are using, such information may consist of your name, current job title, company address, email address, telephone and fax numbers, correspondence with you, which whitepapers you access, and other information you provide to us.
When using a Mobile App, in addition to contact information, we or our service providers (such as mobile operating system and platform providers) may also collect information relating to your device, including your device model, operating system, browser type, unique device identifier, IP address, mobile phone number, mobile network carrier, location, and the way you are using the Mobile App. The information collected will depend on the functionality of the specific Mobile App you are using. If any other information is collected relating to your use of a Mobile App, such information will be specified in the Mobile App.
We may also collect personal information if you register for the Website using a third-party social network account (e.g., LinkedIn, Facebook, and Twitter). For example, the Website or a Mobile App may allow you to login using your social network account credentials. We may collect the username associated with that social media account and any information or content you have permitted the social media network to share with us, such as your profile picture, email address, and birthday. The information we collect may depend on the privacy settings you have with the social network site, so please review the privacy statement or policy of the applicable social network site. When you access the Website through your social network account, you are authorizing us to collect and use your information in accordance with this Privacy Policy.
The Website may also collect content that you provide, including postings on blogs, forums, wikis and other social media applications and services that we may provide.
We may also collect your personal information from data brokers in connection with our marketing activities.
We do not seek to collect sensitive personal information (i.e., data relating to race or ethnic origin, religious or philosophical beliefs, trade union membership, political opinions, medical or health conditions, or information specifying the sex life or sexual orientation of an individual) from users. We will, where necessary, obtain your explicit consent to collect and use such information.
Log information, cookies and Web beacons
The Website and Mobile Apps collect standard Internet log information including your IP address, browser type and language, access times and referring website addresses. To ensure that the Website, Mobile Apps and Communications are well managed and to facilitate improved navigation, we or our service provider(s) may also use cookies (small text files stored in a user’s browser) or Web beacons (electronic images that allow us to count users who have accessed particular content and to access certain cookies) to collect aggregate data.
Information use
We collect and use your personal information with your consent to provide you with access to the Website, Mobile Apps and Communications, or where we have a legitimate business interest in or other legal basis for, such collection and use. The personal information you submit to us may be used to manage our relationship with you, including any of your requests, or to customize or improve the Website or a Mobile App and related services offered to you.
We may also use your personal information for marketing purposes, or to send you promotional materials or communications regarding services provided by us or PWR that we feel may be of interest to you. We may also contact you to seek feedback on services provided by us or PWR for market or other research purposes. Your personal information may also be used to protect our rights or property and that of our users.
You may at any time request that we discontinue sending you Communications, emails or other correspondence.
Disclosure of information to third parties
We may provide your personal information to PWR in order to provide you with information that could be of interest to you and conduct market or other research. Your personal information may also be disclosed to other third parties: in order to respond to your requests or inquiries; as part of a corporate transaction (such as a sale, divestiture, reorganization, merger or acquisition); or where those parties handle information on our behalf.
Personal information may also be disclosed to law enforcement, regulatory or other government agencies, or to other third parties, in each case to comply with legal, regulatory, or national security obligations or requests.
In relation to Mobile Apps, we may also share your usage and personal information with mobile carriers and platform providers, as well as any other entities described in any particular Mobile App in connection with the operation of the Mobile App.
In relation to Communications, we may also share your personal information with service providers in connection with the delivery of such Communications.
All of these disclosures may involve the transfer of personal information to countries or regions without data protection rules similar to those in effect in your area of residence.
By providing information with respect to a Communication or through the Website or a Mobile App, you are consenting to the disclosures described above.
Any personal information that we have referenced above under “Information collection” may be disclosed to the third parties identified in this section for the purposes set forth herein.
Selling of information
We do not sell your personal information that is collected under this Privacy Policy.
Blogs, forums, wikis and other social media
The Website may host various blogs, forums, wikis and other social media applications or services that allow you to share content with other users (collectively Social Media Applications). Any personal information or other information that you contribute to any Social Media Application can be read, collected and used by other users of that Social Media Application over whom we have little or no control. Therefore, we are not responsible for any other user’s use, misuse or misappropriation of any personal information or other information that you contribute to any Social Media Application.
Privacy practices of third parties
This Privacy Policy only addresses the use and disclosure of information collected by Vine Advisors through your interaction with the Website and the Mobile Apps and through other interactions with Vine Advisors relating to a Communication. Other websites or mobile apps that may be accessible through links from the Communication, Website, or Mobile Apps have their own privacy statements and personal information collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by these other parties prior to providing them with information.
Information retention
We retain personal information as necessary for the duration of the purpose outlined in this Privacy Policy. Notwithstanding the duration of the purpose, we may retain your information if necessary to comply with our legal or professional obligations, enforce our agreements, or resolve disputes.
Rights to access and control your personal information
You have choices about how your personal information is collected, used and shared.
If you choose to register for a Communication or with the Website or a Mobile App, you may access your user profile, correct and update your details, or unsubscribe at any time. If you decide that you no longer wish to have your third-party social network site account (e.g., LinkedIn, Facebook, or Twitter) linked to your profile on the Website or a Mobile App, you may change your account settings at any time.
Depending on the jurisdiction in which you are located, you may have the right to request that we modify, delete, or stop processing your personal information, and you may also have the right to request that we provide the following information regarding the personal information we hold about you:
- The categories and/or specific pieces of personal information we collected
- The categories of sources from which personal information is collected
- The business or commercial purpose for collecting personal information
- The categories of third parties with whom we shared personal information
To exercise any of your rights under applicable law described above regarding your personal information, please contact us at +1-713-244-8680. Be prepared to provide your full name, mailing address, and email address.
Applicable laws may also give you the right to lodge a complaint with a local supervisory authority related to this Privacy Policy.
We will not discriminate against you for exercising any of your rights with respect to your personal information.
Verification of Personal Information Request
For certain personal information requests, we must first verify your identity before processing your request. To do so, we may ask you to provide us with your full name, contact information, and relationship to Vine Advisors. Depending on your request, we may ask you to provide additional information. Once we receive this information, we will then review it and determine whether we are able to match it to the information Vine Advisors maintains about you to verify your identity.
Third Party Requests
If you are submitting a personal information request on behalf of someone other than yourself, please contact us please contact us at +1-713-244-8680. You will be asked to provide proof that you are authorized to make the request. This may be in the form of a written authorization signed by the person whom you are acting on behalf of or a valid power of attorney.
Information security
We have in place reasonable commercial standards of technology and operational security to protect all personal information provided by users with respect to Communications, or via the Website or Mobile Apps, from unauthorized access, disclosure, alteration or destruction.
Children’s privacy protection
We understand the importance of protecting children’s online privacy. Communications, the Website and Mobile Apps are not designed for or intentionally targeted at children under the age of 18. It is not our policy to intentionally collect or maintain information about anyone under the age of 18. If we obtain actual knowledge that we have received such information, we will take steps to delete it.
Changes to our Privacy Policy
In addition to describing our current privacy practices, this Privacy Policy also describes the categories of personal information we collected, disclosed, or sold during the preceding 12 months. We may modify or amend this Privacy Policy from time to time at our discretion. When we make changes to this Privacy Policy, we will amend the revision date at the top of this page and such modified or amended Privacy Policy shall be effective as to you and your information as of that revision date. We encourage you to periodically review this Privacy Policy to view any updates.
Contact information
If you have any questions or concerns regarding your privacy while using the Website or a Mobile App, or upon receipt of a Communication, please contact us at +1-713-244-8680.
